Short-Lived
Climate
Pollutant
Redu
ction Strategy
March 2017
This report has been reviewed by the staff of the California Air Resources Board and
approved for publication. Approval does not signify that the contents necessarily reflect the
views and policies of the Air Resources Board, nor does mention of trade names or
commercial products constitute endorsement or recommendation for use.
March 14, 2017
Table of Contents
EXECUTIVE SUMMARY ................................................................................................. 1
I. Introduction: Showing the Way to 2
o
C .................................................................... 17
A. Significant Benefits from Accelerated Action to Cut SLCP Emissions ............. 19
B. Building on California’s Air Quality and Climate Leadership ............................ 21
C. Purpose of SLCP Reduction Strategy .............................................................. 22
D. Achieving Science-Based Targets ................................................................... 23
E. Coordinating Research Efforts Related to SLCPs ........................................... 24
F. Process for Developing the SLCP Reduction Strategy .................................... 25
II. California’s Approach to Reducing SLCP Emissions .............................................. 27
A. Prioritize Actions with Diverse Benefits ............................................................ 27
B. Put Organic Waste to Beneficial Use ............................................................... 28
C. Identify Practical Solutions to Overcome Barriers ............................................ 29
D. Invest in SLCP Emission Reductions and Communities .................................. 31
E. Advance the Science of SLCP Sources and Emissions................................... 33
F. Need for Focused SLCP Programs.................................................................. 34
III. Latest Understanding of Science on SLCPs ........................................................... 36
A. Black Carbon ................................................................................................... 41
B. Methane ........................................................................................................... 42
C. Fluorinated Gases (Hydrofluorocarbons) ......................................................... 43
IV. Reducing Anthropogenic Black Carbon Emissions ................................................. 45
A. Progress to Date .............................................................................................. 47
B. Recommended Actions to Further Reduce Black Carbon Emissions .............. 54
V. Reducing Methane Emissions ................................................................................ 56
A. Progress to Date .............................................................................................. 56
B. Recommended Actions to Further Reduce Methane Emissions ...................... 61
1. Dairy Manure .......................................................................................... 63
2. Dairy and Livestock Enteric Fermentation .............................................. 70
3. Landfills .................................................................................................. 71
4. Wastewater Treatment and other Miscellaneous Sources ..................... 77
5. Oil and Gas ............................................................................................ 78
VI. Reducing HFC Emissions ....................................................................................... 83
A. Progress to Date .............................................................................................. 84
March 14, 2017
B. Recommended Actions to Further Reduce HFC Emissions ............................ 90
C. Sulfuryl Fluoride ............................................................................................... 96
VII. Achieving Success ................................................................................................. 99
A. Integrate and Coordinate Planning .................................................................. 99
B. Support Local and Regional Leadership ........................................................ 100
C. Investments ................................................................................................... 102
D. Coordinate with Subnational, Federal, and International Partners ................. 105
VIII. Evaluations ........................................................................................................... 107
A. Economic Assessment of Measures in the SLCP Strategy ............................ 107
1. Residential Wood Combustion Black Carbon Emission Reductions .... 109
2. Methane Emission Reductions from Dairy Manure .............................. 113
3. Methane Emission Reductions from Diversion of Landfill Organic
Waste ................................................................................................... 125
4. Greenhouse Gas Emission Standards for Crude Oil and Natural Gas
Facilities Regulation ............................................................................. 129
5. Hydrofluorocarbon (HFC) Emission Reductions ................................... 130
B. Public Health Assessment ............................................................................. 132
C. Environmental Justice and Disadvantaged Communities .............................. 136
D. Environmental Analysis .................................................................................. 142
IX. Next Steps ............................................................................................................ 144
Appendices
Appendix A: Senate Bill 605 (Lara, Chapter 523, Statutes of 2014)
Appendix B: Senate Bill 1383 (Lara, Chapter 395, Statues of 2016)
Appendix C: California SLCP Emissions
Appendix D: Research Related to Mitigation Measures
Appendix E: Final Environmental Analysis prepared for the Revised Proposed
Short-Lived Climate Pollutant Reduction Strategy
Appendix F: Supporting Documentation for the Economic Assessment of Measures in
this SLCP Strategy
1 March 14, 2017
EXECUTIVE SUMMARY
California's dramatic landscapes—including deserts, mountains, valleys, and
coastlines—and abundant natural resources, have drawn early explorers and settlers
and today's residents. However, climate change is threatening Californian's way of life.
The State suffers through historic temperatures, persistent droughts, and more intense
and frequent wildfires. Each year
seems to bring a new global
temperature record, and new
evidence suggests sea levels are
rising much faster than predicted.
What was once, and remains, a
generational problem of
greenhouse gas (GHG) balance in
the atmosphere has now become
an immediate threat to our
California lifestyle.
The only practical way to rapidly
reduce the impacts of climate
change is to employ strategies
built on the tremendous body of
science. The science
unequivocally underscores the
need to immediately reduce emissions of short-lived climate pollutants (SLCPs), which
include black carbon (soot), methane (CH
4
), and fluorinated gases (F-gases, including
hydrofluorocarbons, or HFCs). They are powerful climate forcers and harmful air
pollutants that have an outsized impact on climate change in the near term, compared
to longer-lived GHGs, such as carbon dioxide (CO
2
)
.
SLCPs are estimated to be
responsible for about 40 percent of current net climate forcing. Action to reduce these
powerful “super pollutants” today will provide immediate benefits as the effects of our
policies to reduce long-lived GHGs further unfold.
California’s Global Warming Solutions Act, AB 32 (Nuñez, Chapter 488, Statutes of
2006), charges the California Air Resources Board (ARB or Board) with reducing
statewide GHG emissions to 1990 emission levels by 2020 and maintaining a statewide
GHG emission limit, while seeking continuing GHG emission reductions. In September
2016, Governor Brown signed SB 32 (Pavley, Chapter 249, Statutes of 2016), codifying
a reductions target for statewide GHG emissions of 40 percent below 1990 emission
levels by 2030. SLCP emission reductions will support achieving these targets. Indeed,
specific to SLCP emission reductions, Senate Bill 605 (Lara, Chapter 523, Statutes of
2014) requires the ARB to develop a plan to reduce emissions of SLCPs, and Senate
Bill 1383 (Lara, Chapter 395, Statutes of 2016) requires the Board to approve and begin
implementing the plan by January 1, 2018. SB 1383 also sets targets for statewide
reductions in SLCP emissions of 40 percent below 2013 levels by 2030 for methane
and HFCs and 50 percent below 2013 levels by 2030 for anthropogenic black carbon,
2 March 14, 2017
as well as provides specific direction for reductions from dairy and livestock operations
and from landfills by diverting organic materials.
This final proposed SLCP Reduction Strategy (SLCP Strategy) was developed pursuant
to SB 605 and SB 1383 and lays out a range of options to accelerate SLCP emission
reductions in California, including regulations, incentives, and other market-supporting
activities. The SLCP Strategy will inform and be integrated into the upcoming 2017
Climate Change Scoping Plan Update, which will incorporate input from a wide range of
stakeholders to develop a comprehensive plan for achieving the SB 32 statewide 2030
GHG limit of 40 percent below 1990 levels. The process for updating the Scoping Plan
began in fall 2015 and is
scheduled for completion in
2017.
Scientific research indicates that
an increase in the global
average temperature of 2°C
(3.6°F) above pre-industrial
levels, which is only 1.1°C
(2.0°F) above present levels,
poses severe risks to natural
systems and human health and
well-being. Deploying existing
technologies and resource
management strategies globally
to reduce SLCP emissions can
cut the expected rate of global
warming in half and keep
average warming below the
dangerous 2
o
C threshold at
least through 2050. We can
slow sea level rise significantly,
reduce disruption of historic
rainfall patterns, and boost agricultural productivity by reducing crop losses to air
pollution. Cutting global SLCP emissions immediately will slow climate feedback
mechanisms in the Arctic and elsewhere that would otherwise further accelerate global
warming and make climate change far more difficult to solve and far more costly to live
with—as more resources would be required for disaster relief, conflict management, and
adaptation. Most importantly, we can dramatically reduce global air pollution, saving
millions of lives each year. Many of these benefits will primarily accrue in regions and
populations disproportionately impacted by climate change, including the developing
world.
Using cost-effective and available technologies and strategies, worldwide anthropogenic
sources of SLCP emissions can be largely controlled by 2030 and the global benefits of
a collective commitment to substantially reduce SLCP emissions would be profound.
Leading efforts by California, the United States, Mexico, Norway, Europe, the Arctic
3 March 14, 2017
Council, and several countries and non-
governmental entities acting through the Climate
and Clean Air Coalition to Reduce Short-Lived
Climate Pollutants (CCAC) are already targeting
SLCPs. Many other countries included SLCP
emissions in their commitments made at the Paris
climate conference, or are targeting them through
separate policies to improve air quality and
promote sustainable agriculture and
transportation, among other efforts.
Assembly Bill 1613 (Committee on Budget,
Chapter 370, Statutes of 2016) and Senate Bill
859 (Committee on Budget and Fiscal Review,
Chapter 368, Statutes of 2016) lays out a spending plan for Cap-and-Trade revenues
which specifically target SLCP emission reductions. These include $5 million for black
carbon wood smoke reductions, $40 million for waste reduction and management,
$7.5 million for Healthy Soils, and $50 million for methane emission reductions from
dairy and livestock operations.
An Opportunity for California
In this SLCP Strategy, we outline SLCP emission reduction actions that provide a wide
array of climate, health, and economic benefits throughout the State. The State's
organic waste should be put to beneficial use, such
as for soil amendments/compost, electrical
generation, transportation fuel, and pipeline-injected
renewable natural gas. Organic wastes converted to
biogas could supply enough renewable natural gas
for about 2 million residential units.
1
Practical
solutions must be developed and implemented to
overcome barriers to waste gas utilization for pipeline
injection and grid interconnection. Additional data on
SLCP sources must be collected in order to improve
California's SLCP emission inventory and better
understand potential mitigation measures. Finally,
the State should provide incentives to accelerate
market transitions to cleaner technologies that foster
significant system-wide solutions to cut emissions of
SLCPs. Many of the sources and sectors responsible
for SLCP emissions are concentrated in communities
with high levels of pollution or unemployment, which
could especially benefit from targeted investments to
1
For illustrative purposes only. This SLCP Strategy calls for a variety of waste management approaches,
some of which do not yield energy products.
4 March 14, 2017
improve public health and boost economic growth.
In the coming years, many billions of dollars in public and private investments are
anticipated to support efforts to reduce SLCP and CO
2
emissions and support our
agricultural and waste sectors, build sustainable freight systems, and encourage low-
Global Warming Potential (GWP) refrigerants. These investments will strengthen the
State as a whole and the communities where they occur. Many of the benefits will
accrue in the Central Valley, rural parts of the State, or other areas disproportionately
impacted by pollution, such as those along freight corridors.
Stubborn barriers remain, including connecting distributed electricity and biogas
projects, which have slowed previous efforts to reduce emissions of SLCPs and capture
a wide array of benefits. These barriers are not insurmountable, and now is the time to
solve them. State agencies, utilities, and other stakeholders need to work immediately
to identify and resolve remaining obstacles to connecting distributed electricity with the
grid and injecting renewable natural gas into the pipeline, as called for in SB 1383.
Supporting the use of the cleanest technologies with funding and strategies that
maximize air quality, climate, and water quality benefits can accelerate their
introduction. Building market certainty and value for the energy, soil amendment, and
other products such as a uniform fertilizer that come from compost or anaerobic
digestion facilities will help to secure financing to accelerate and scale project
development.
Building on California Leadership
This SLCP Strategy builds on California’s ongoing leadership to address climate change
and improve air quality. It has been developed with input from State and local agencies,
academic experts, a working group of agricultural experts and farmers convened by the
California Department of Food and Agriculture (CDFA), businesses, and other
interested stakeholders in an
open and public process.
ARB and State agencies
collaborated to identify
reduction measures for
specific sectors, including the
dairy, wastewater, and waste
sectors. In addition, ARB
collaborated with the local air
districts to identify SLCP
emission reduction measures
that could be implemented
through district action.
Throughout this process,
ARB has sought advice from
academic, industry, and
environmental justice
5 March 14, 2017
representatives. Additionally, ARB staff is working closely with manufacturers to
determine the feasibility and cost of replacement products for high-GWP refrigerants,
and with the dairy industry and academics to evaluate options and costs for reducing
emissions of methane at dairies.
While reducing GHG emissions is a key objective for the State, California remains
committed to further reducing emissions of criteria (smog-forming) pollutants and toxic
air pollutants, as well. Many of the concepts described in this SLCP Strategy have
already been discussed in the context of the California Sustainable Freight Action Plan,
2016 Mobile Source Strategy and other efforts related to developing State
Implementation Plans for air quality, and plans for bioenergy, waste management, water
management, healthy soils, and sustainable management of the state’s natural
resources.
State agencies and the air districts are committed to continuing to work together to
ensure that the concepts outlined in this SLCP Strategy are implemented in a
coordinated and synergistic way. The sections below describe goals, regulations,
incentives, and other efforts that would:
Encourage national and international deployment of California’s well-established
and proven measures to reduce black carbon emissions;
Further reduce black carbon emissions from off-road and non-mobile sources;
Significantly cut methane emissions from dairy and livestock operations while
providing farmers with new, potentially lucrative revenue streams;
Significantly reduce disposal of organics in landfills and create and expand
industries to capture value from organic waste resources in California;
Significantly reduce fugitive methane emissions from oil and gas systems and
other sources; and
Accelerate the transition to low-GWP refrigerants and more energy efficient
refrigeration systems.
Achieving Significant Emission Reductions
SB 1383 sets statewide emission reduction targets of 40 percent below 2013 levels by
2030 for methane and HFCs, and 50 percent below 2013 levels by 2030 for
anthropogenic black carbon emissions, codifying the proposed targets included in
earlier versions of this SLCP Strategy. These targets will assist the State in meeting its
SB 32 goals and federal air quality standards for 2031 and beyond.
The emission reductions associated with these targets are summarized in Table 1. The
goals and proposed measures included in this SLCP Strategy will reduce SLCP
emissions to levels in line with these targets. Recognizing how damaging SLCPs can
be over the short-term, 20-year GWPs are used in this report to quantify emissions of
SLCPs, as opposed to 100-year GWPs, which are used in the State’s official GHG
inventory and for accounting for emissions in programs adopted under AB 32.
6 March 14, 2017
Table 1: California SLCP Emissions and Emission Reduction Target Levels
(MMTCO2e)*
2013
2030 BAU**
2030 Emission
Reduction Target
(percent reduction from
2013)
38
26
19 (50%)
118
117
71 (40%)
40
65
24 (40%)
*Using 20-year GWPs from the 4
th
Assessment report of the IPCC for methane and HFCs, and 5
th
Assessment report for black carbon (the first report to define a GWP for black carbon)
**Business As Usual (BAU) forecasted inventory includes reductions from implementation of current
regulations
Black Carbon
Black carbon is not one of the climate pollutants originally included in international
climate frameworks, and it is not included in California’s AB 32 inventory. However,
recent studies have shown that black carbon plays a far greater role in global warming
than previously believed. California has made tremendous progress in reducing black
carbon emissions as part of its efforts to reduce carcinogenic diesel particulate matter
emissions and improve air quality. California
has already cut anthropogenic black carbon
emissions by over 90 percent since the 1960s,
and existing measures are projected to cut
mobile source emissions by 75 percent and
total anthropogenic emissions by nearly
60 percent between 2000 and 2020. Putting
measures in place to achieve similar levels of
reductions worldwide is the quickest way to
reduce the impacts of climate change, and
would save millions of lives per year.
These reductions have come from strong efforts to reduce on-road vehicle emissions,
especially diesel particulate matter. Car and truck engines used to be the largest
sources of anthropogenic black carbon emissions in California, but the State's existing
air quality policies will virtually eliminate black carbon emissions from on-road diesel
engines within 10 years. These policies are based on existing technologies, which
could be deployed throughout the U.S. and the world.
With the large reduction in emissions of black carbon from vehicles, other sources of
black carbon emissions will become more significant contributors to the State’s black
carbon inventory over time. In particular, without additional actions, off-road mobile, fuel
combustion in the industrial and power sectors, and woodstoves and fireplaces will
account for more than three-quarters of anthropogenic black carbon emissions in
7 March 14, 2017
California in 2030. However, black carbon emissions from these sources have declined
significantly as well, by almost 30 percent since 2000. Continued progress on these
sectors—transitioning to cleaner and more efficient uses of energy, reducing emissions
from woodstoves and fireplaces, taking steps to meet federal health-based air quality
standards by 2031, and developing and implementing a sustainable freight system—will
continue to reduce black carbon emissions and should allow us to meet the targets
established in this SLCP Strategy. The State’s 2016 Mobile Source Strategy, 2017
Scoping Plan Update, and Sustainable Freight Action Plan, a multi-agency effort to
deploy a sustainable and efficient system for goods movement, will build on these
measures to reduce black carbon. Additionally, ARB will work with local air districts to
further reduce particulate matter and black carbon emissions from woodstoves and
fireplaces. Last year, Governor Brown signed legislation allocating $5 million to reduce
black carbon from wood smoke.
Wildfire is the largest source of black carbon in California, harmfully impacting both
public health and the climate. In general, wildfires are occurring at increasing rates and
at increasing levels of severity. This trend raises concern over the long-term resilience
of these forests and their ability to sequester carbon, mitigate climate change, and
provide resource amenities. Since the legislative direction and intent of SB 1383 is to
include only anthropogenic, non-forest, sources of black carbon in the target, and in
light of continued state research and policy development occurring in this area, a target
for forest-derived black carbon emission reductions is not included in this SLCP
Strategy. The Forest Carbon Plan, as well as the 2017 Scoping Plan Update, will
continue to explore the interrelation of climate change and natural lands and lay out
programmatic and scientific actions needed to increase carbon sequestration and
decrease black carbon emissions from wildfire. Implementation of these plans is
important to address emissions from California forest fires, and to address forest health
generally, from both a public health and climate change perspective.
Methane
Methane is responsible for about 20 percent of current net climate forcing globally. In
California, about half of methane emissions come from dairy and livestock manure or
organic waste streams that are landfilled. These resources could be put to valuable use
as sources of renewable energy or fuel, soil amendments, and other products. The
other half mostly comes from enteric fermentation (burps) from dairy cows and livestock
and fugitive emissions (leaks) from oil production, processing, and storage, gas pipeline
system, or industrial operations. California can cut methane emissions by 40 percent
below current levels in 2030 by capturing or altogether avoiding methane from manure
at dairies, pursuing opportunities to reduce methane emissions from enteric
fermentation, significantly reducing disposal of organics in landfills, and reducing fugitive
methane emissions by 40-45 percent from all sources.
Strong market support and broad collaboration among State agencies, industry, and
other stakeholders will be necessary to reduce landfill and manure methane emissions
by putting organic waste streams to beneficial use. The State will support early action
8 March 14, 2017
to build infrastructure capacity and reduce emissions through existing incentives and
accelerated efforts to overcome barriers and foster markets. Government agencies and
stakeholders will work to foster market conditions to support private sector investment in
expanded or new infrastructure, including building markets for compost, soil
amendments, and low carbon transportation fuels; overcoming barriers to pipeline
injection of biomethane, grid connection for electricity or another best-use alternative;
and identifying effective financing mechanisms and levels to reach the goals in this
SLCP Strategy.
Ultimately, a combination of incentives, State and private sector collaboration and
investment, and regulations will be necessary to capture the value in organic waste
streams and ensure lasting emission reductions in order to achieve an economy-wide
40 percent reduction in methane.
Manure is responsible for 25 percent of California’s methane emissions and improved
manure management offers significant, near-term potential to achieve deep reductions
in the State’s methane emissions. Before ARB regulates dairy and livestock manure
emissions, as required by SB 1383, California agencies will encourage and support
near-term actions by dairies to reduce manure emissions through financial incentives,
collaboration to overcome barriers, development of policies to encourage renewable
natural gas production, and other market support.
Enteric fermentation from all livestock is responsible for roughly 30 percent of the
State’s methane emissions and is a critical source to control, but development of
effective control measures face a unique set of challenges. The State will support and
monitor research and explore voluntary, incentive-based approaches to reduce enteric
fermentation emissions from dairy and non-dairy livestock sectors until cost-effective
and scientifically-proven methods to reducing these emissions are available and
regulatory actions can be evaluated.
Any regulations will be developed according to the time frames and requirements set
forth in SB 1383 and AB 32, and in coordination with CDFA, CPUC, and local air quality
and water quality agencies. The development of measures to reduce methane will be
done in close coordination with dairy industry and will consider public input; available
financial incentives; technical, market, and regulatory barriers to the development of
dairy methane emission reduction projects; research on dairy methane emission
reduction projects; and the potential for emissions leakage. A key effort will include
working with CPUC and the dairy industry to implement a series of pilot projects that will
help to better inform the opportunities for economically viable methane reduction
strategies as well as the barriers that must be addressed. SB 1383 stipulates that
manure methane emission control regulations are to be implemented on or after
January 1, 2024. However, the statute allows ARB to require monitoring and reporting
of emissions from dairy and livestock operations before that date. Consistent with
SB 1383, ARB, in consultation with CDFA, will analyze the progress dairies are making
in achieving the goals in this SLCP Strategy by July 1, 2020, and may adjust those
goals as necessary.
9 March 14, 2017
For organic waste currently landfilled, the California Department of Resources
Recycling and Recovery (CalRecycle) will consult with ARB to develop regulations by
late 2018 to reduce the level of the statewide disposal of organic waste by 50 percent of
2014 levels by 2020 and 75 percent of 2014 levels by 2025. These regulations will take
effect on or after January 1, 2022. CalRecycle plans to consider the regulations for
adoption by the end of 2018, which will: 1) allow jurisdictions that want to adopt early
the ability to do so, thus contributing to the 2020 goal; and 2) provide clear direction to
all jurisdictions, their service providers, and regulated businesses so that they can plan
and budget for the required program changes that will need to take effect in 2022.
To support this, CalRecycle, with assistance from ARB, will build on its partnerships
with local governments, industry, nonprofits, local air districts and water boards to
support regional planning efforts and identify ways to increase recovery of organics and
to safely and effectively develop necessary organics recycling capacity. Key issues
associated with increasing actual recycling capacity include quantifying the co-benefits
and the GHG emission reduction benefits of applying compost, addressing the cross-
media regulatory tradeoffs between product use benefits relative to compost facility
impacts, making beneficial use of biomethane generated from anaerobic digestion
projects, and overcoming difficult issues associated with siting, social acceptance,
CEQA mitigation, and other issues associated with new organics processing facilities.
Under SB 1383, 20 percent of the edible food destined for the organic waste stream is
to be recovered to feed people in need by 2025. CalRecycle will explore new ways to
foster food waste prevention and edible food recovery. Recovering and utilizing edible
food that would otherwise be landfilled can help to reduce methane emissions and
increase access to healthy foods for millions Californians lacking access to an adequate
food supply. Additionally, CalRecycle and ARB will work with the State and regional
Water Boards to assess the feasibility and benefits of actions to require capturing and
effectively utilizing methane generated from wastewater treatment, and opportunities for
co-digestion of food waste at existing or new
anaerobic digesters at wastewater treatment
plants.
This SLCP Strategy also establishes a goal of
reducing fugitive methane emissions from oil
and gas by 40 percent below current levels in
2025 and a minimum 45 percent in 2030, and
from all other sources by 40 percent in 2030.
This aligns with the federal government's goal
of reducing methane emissions from oil and gas
operations by 40–45 percent below 2012 levels by 2025.
California has a comprehensive and stringent emerging framework to reduce methane
emissions from oil and gas systems. ARB is developing a regulation to reduce fugitive
methane emissions from the oil and gas production, processing and storage sector,
10 March 14, 2017
which will be among the most stringent such regulations in the country. Additionally,
pursuant to Senate Bill 1371 (Leno, Chapter 525, Statutes of 2014), the California
Public Utilities Commission (CPUC) has launched a rulemaking to minimize methane
leaks from natural gas transmission and distribution pipelines. Increases in energy
efficiency and renewable energy, as well as more dense development patterns, will
reduce oil and gas demand and fugitive emissions.
ARB and the California Energy Commission (CEC) have also conducted several
research projects to improve methane emission monitoring and accounting, as well as
identify emission “hotspots,” which are responsible for large fractions of total fugitive
emissions. In addition, AB 1496 (Thurmond, Chapter 604, Statutes of 2015) requires
ARB, in consultation with the local air districts, to monitor and measure high-emission
methane hot spots in the State. These efforts will continue, and are critical to
accelerating leak detection and fugitive methane emission reductions from all sectors,
not just oil and gas. Ultimately, to eliminate fugitive methane emissions, the State
needs to transition away from its use of oil and natural gas.
HFCs
Fluorinated gases, and in particular HFCs, are the fastest-growing source of GHG
emissions in California and globally. More than three-quarters of HFC emissions in
California come from the use of refrigerants in the commercial, industrial, residential,
and transportation sectors. In many cases, alternatives with much lower GWPs are
already available and the United States Environmental Protection Agency (U.S. EPA) is
beginning to impose bans on the use of F-gases with the highest GWPs in certain
applications and sectors.
The annual Montreal Protocol Meeting of Parties in October 2016 in Kigali, Rwanda,
resulted in an historic international agreement, known as the “Kigali Amendment”, to
phase down the production of HFCs globally. The agreement requires a reduction in
the production and supply of HFCs for developed countries, including the U.S., from
2011-2013 levels, as follows: 10 percent reduction in 2019; 40 percent in 2024,
70 percent in 2029, 80 percent in 2034, and 85 percent in 2036. Developing countries
will not have to begin the phasedown until 2029, and will be allowed until 2045 to reach
the 85 percent reductions in HFC consumption. Although the HFC phasedown will
eventually result in significant reductions, preliminary ARB analysis indicates that the
phasedown alone is not sufficient to reach California’s HFC emission reduction goals by
2030 for the following reasons:
1) The current oversupply of HFCs in the U.S. (as a result of “dumping” imports of
HFCs at less than fair market value) will ensure that the supply of HFCs is higher than
demand at the beginning of the phasedown in 2019;
11 March 14, 2017
2) The initial cap on HFC production and consumption is estimated to be much higher
than the demand, delaying the transition to lower-GWP alternatives, and therefore
delaying emission reductions;
2
3) Existing equipment using high-GWP HFCs has an average lifetime of 15-20 years,
and can be expected to continue operating and emitting high-GWP HFCs well past
2030. The relatively long equipment life is responsible for a long lag time of 10-20 years
between a production phase-out and an equivalent emission reduction;
3
4) Without diligent national enforcement efforts by the U.S. EPA, illegal imports of high-
GWP HFCs into the U.S. from developing countries may be a significant issue, as
developing countries do not start an HFC phasedown until 2029, and imported HFCs
are likely to be much less expensive. A similar problem occurred in the U.S. in the
1990s when ozone-depleting refrigerants were banned but continued to be illegally
imported into the U.S.
4
ARB will continue to work with industry representatives to evaluate the impact of the
Kigali Amendment on HFC emissions and reductions in California, especially as they
pertain to meeting the 40 percent emission reduction goal. The assessment will be
available later in 2017 for public and scientific peer review. The results of the
assessment will be considered in future rulemaking processes. ARB will focus on
measures that can move low-GWP alternatives and technologies forward both
nationally and internationally. For example, as effective alternatives become available,
ARB will consider developing limitations on the use of high-GWP refrigerants in new
refrigeration and air-conditioning equipment where lower-GWP alternatives are feasible
and readily available. California's climate zones range from high alpine to hot desert
environments. As such, California could be instrumental as a proving ground for low-
GWP refrigeration and air-conditioning technologies that can be used in extreme
environments around the world.
A summary of all proposed SLCP emission reduction measures and estimated
reductions is presented in Table 2. These estimates may change as more information
on emission sources becomes available and as programs or regulations are developed.
2
ARB analysis February 2017. The HFC cap baseline will be finalized by the U.S. EPA by Jan. 2018.
3
Gallagher, et al., 2014. “High-global Warming Potential F-gas Emissions in California: Comparison of
Ambient-based versus Inventory-based Emission Estimates, and Implications of Estimate Refinements”.
Glenn Gallagher, Tao Zhan, Ying-Kuang Hsu, Pamela Gupta, James Pederson, Bart Croes, Donald R.
Blake, Barbara Barletta, Simone Meinardi, Paul Ashford, Arnie Vetter, Sabine Saba, Rayan Slim, Lionel
Palandre, Denis Clodic, Pamela Mathis, Mark Wagner, Julia Forgie, Harry Dwyer, and Katy Wolf .
Environmental Science and Technology 2014, 48, 1084−1093. Available at
dx.doi.org/10.1021/es403447v (accessed 28 January 2016).
4
EIA, 2005. Environmental Investigation Agency (EIA). “Under the Counter – China’s Booming Illegal
Trade in Ozone-Depleting Substances”, by Ezra Clark. December, 2005. Emerson Press, ISBN 0-
9540768-2-6. Available at: https://eia-international.org/wp-content/uploads/Under-The-Counter-Dec-
05.pdf.
12 March 14, 2017
Table 2: Summary of Proposed New SLCP Measures and Estimated Emission
Reductions (MMTCO2e)
1
Measure Name
2030 Annual
Emission
Reductions
2030 Annual Emissions
BLACK CARBON (ANTHROPOGENIC)
2030 BAU
2
26
Residential Fireplace and
Woodstove Conversion
3
State Implementation Plan
Measures and Clean Energy
Goals
3
4
2030 BAU with new measures
19
METHANE
2030 BAU
2
117
Dairy and Other Livestock (Manure
and Enteric Fermentation)
26
Landfill
4
Wastewater, industrial and Other
Miscellaneous Sources
7
Oil and Gas Sector
8
2030 BAU with new measures
71
4
HYDROFLUOROCARBONS
2030 BAU
2
65
Financial Incentive for Low-GWP
Refrigeration Early Adoption
2
HFC Supply Phasedown (to be
achieved through the global HFC
phasedown)
5
19
Prohibition on sales of very-high
GWP refrigerants
5
Prohibition on new equipment with
high-GWP Refrigerants
15
2030 BAU with new measures
24
1
Using 20-year GWPs from the 4
th
Assessment report of the IPCC for methane and HFCs, and 5
th
Assessment report for black carbon (the first report to define a GWP for black carbon)
2
Business As Usual (BAU) forecasted inventory includes reductions from implementation of
current regulations
3
Future emission reduction measures that will be developed to help the State meet its air quality
and climate change goals are also expected to help the State meet the black carbon target by
2030
4
The specific annual reduction values shown above do not sum exactly to the total shown due to
rounding error.
5
A global HFC production and consumption phasedown was agreed to on October 15, 2016, in
Kigali, Rwanda. ARB is currently evaluating the impact upon HFC emission reductions in
California and plans to utilize the results from the assessment to inform future updates to BAU
projections for HFC emissions.
13 March 14, 2017
Cost-Effective Measures with Significant Health Benefits
Significantly reducing SLCP emissions in line with the targets presented in this SLCP
Strategy will continue California’s long and successful legacy of implementing
innovative and effective environmental and health policies while fostering the growth of
a vibrant and sustainable economy. The proposed actions in this SLCP Strategy can
contribute to health, environmental, and economic benefits that will positively impact
Californian businesses and individuals. As California industry and households shift to
cleaner technologies, many benefits will be concentrated in disadvantaged communities
or other parts of the State most in need of economic development opportunities. The
San Joaquin Valley, rural areas where wood smoke is a primary health concern, and
communities along freight corridors are anticipated to see improvements in health as
well as green job growth and environmental benefit.
Collectively, implementing these measures would bring thousands of jobs from several
billion dollars of investment in clean technologies and strategies that would lead to
significant reductions in SLCP emissions. Potential revenues and efficiency savings
could also be significant—and potentially outweigh the costs of some measures. In
particular, for projects that utilize organic waste to create transportation fuel, the value
of Low Carbon Fuel Standard (LCFS) credits and RIN credits from the federal
Renewable Fuel Standard can make these projects profitable. However, there remain
market barriers that must be addressed, and continued incentives and State support
can help to demonstrate and scale these strategies. In other cases, there may be net
costs, but associated SLCP emission reductions may come at relatively low cost or
provide other environmental and health benefits. For example, strategies at dairies that
may not include energy production and associated revenues can still reduce emissions
at low cost, and may deliver other environmental benefits, as well. And the collection of
HFC measures identified in this SLCP Strategy could significantly reduce GHG
emissions through 2030 at a very low cost per tonne.
Achieving the targets identified in this SLCP Strategy would help reduce ambient levels
of ozone and particulate matter, and the cardiovascular and respiratory health effects
associated with air pollution. These and other health benefits can be maximized as part
of an integrated approach to ensure that strategies used to reduce SLCP emissions
also help to improve air quality and water quality on a regional basis. Many of these
benefits would accrue in disadvantaged communities, which are often located near
sources of SLCP emissions.
The proposed actions are supported through an integrated set of air quality and climate
policies in the State, including the LCFS, Bioenergy Feed-In-Tariff, utility investments to
defray the costs of connecting renewable natural gas supplies to the pipeline, and direct
investments from State funds. Together, and with additional targeted State support, we
can meet the goals identified in this SLCP Strategy and capture additional economic,
environmental and health benefits.
14 March 14, 2017
Putting the Strategy into Action
SB 1383 requires ARB to begin implementing the SLCP Strategy by January 1, 2018,
as well as stipulates timeframes for other requirements (Table 3). ARB staff, along with
staff from other state agencies, have already begun efforts to implement most of these
requirements.
All regulatory measures developed pursuant to the SLCP Strategy would undergo a
complete, public rulemaking process including workshops, and economic and
environmental evaluations. While this SLCP Strategy is intended to be comprehensive,
it is not exhaustive. We will continue to pursue new cost-effective programs and
measures as technology and research on SLCP emission sources and potential
mitigation measures advances. Staff will track the progress of implementation of the
SLCP measures and provide periodic updates to the Board. This information, as well
as updates to the SLCP emission inventory, will be posted to ARB's SLCP website.
Table 3: Timeline for SB 1383 Mandates
Action
Deadline
ARB approves SLCP Strategy and begins Implementation
Expected approval date………………………………………
Statutory deadline…………………………………………….
First Quarter 2017
By January 1, 2018
ARB, CDFA, State Water Resources Control Board and
Regional Water Quality Control Boards in coordination with
the energy agencies, will work with the dairy industry to
establish a dairy workgroup to identify and address barriers
to the collection and utilization of biomethane.
First Quarter 2017 and ongoing
CPUC, in consultation with ARB and CDFA, directs utilities
to develop at least 5 dairy biomethane pipeline injection
projects
By January 1, 2018
ARB develops a pilot financial mechanism to reduce LCFS
credit value uncertainty from dairy-related projects and
makes recommendations to the Legislature to expand the
mechanism to other biogas sources
By January 1, 2018
ARB provides guidance on the impact of regulations on
LCFS credits and compliance offsets
By January 1, 2018
ARB, in consultation with CPUC and CEC, develops policies
to encourage development of infrastructure and biomethane
projects at dairy and livestock operations
By January 1, 2018
CEC develops recommendations for the development and
use of renewable gas as part of its 2017 Integrated Energy
Policy Report
By early 2018
PUC renewable gas policies based on CEC IEPR
Ongoing
15 March 14, 2017
Action
Deadline
ARB, in consultation with CDFA, evaluates the feasibility of
enteric fermentation methane reduction incentives and
regulations and develops regulations as appropriate
Ongoing
CalRecycle adopts an organics disposal reduction regulation
By end of 2018
ARB, in consultation with CDFA, analyzes and reports on
the methane reduction progress of the dairy and livestock
sector
By July 1, 2020
CalRecycle, in consultation with ARB, evaluates progress
towards meeting the 2020 and 2025 organics waste
reduction goals, the status of organics markets and barriers,
and recommendations for additional incentives
By July 1, 2020
CalRecycle implements an organics disposal reduction
regulation
On or after January 1, 2022
ARB begins developing and considers for adoption a
manure management methane reduction regulation
Before January 1, 2024
ARB implements a manure management methane reduction
regulation
On or after January 1, 2024
Effectively implementing this SLCP Strategy will require staff to continue working with
local, regional, federal and international partners, while strategically investing time and
money to overcome market barriers that hinder progress. As our efforts continue, our
progress toward these goals will accelerate, leading to a wide range of significant
economic and environmental benefits for California broadly, and many of the State’s
most disadvantaged communities, specifically.
Implementing the SLCP Strategy will also require continued efforts to overcome barriers
to connecting distributed electricity, generated from renewable natural gas (RNG), to the
grid and injecting renewable natural gas into the pipeline. To address these obstacles,
SB 1383 calls for ARB to establish energy infrastructure development and procurement
policies needed to encourage dairy biomethane projects and calls on the CPUC to
direct gas companies to implement no fewer than five dairy biomethane pilot projects to
demonstrate interconnection to the common carrier pipeline system. The same issues
also apply to organic waste biomethane projects. On a broader scale, SB 1383 requires
CEC to develop recommendations for the development and use of renewable gas as a
part of its 2017 Integrated Energy Policy Report. Based on CEC’s recommendations,
State agencies will strive to meet the State’s climate change, renewable energy, low
carbon fuel, and SLCP goals by considering and adopting policies and incentives to
significantly increase the sustainable production and use of renewable gas. CPUC will
consider additional policies to support the development and use in-State of renewable
gas that reduces SLCPs. These policies shall prioritize fuels with the greatest GHG
emission benefits, taking into account RNG carbon intensity and reductions in SLCP
emissions. In the coming months, the work already underway in these areas will
continue to gain momentum.
16 March 14, 2017
Finally, the State will only realize the full benefits of strong action to reduce SLCP and
CO
2
emissions if others take committed action, as well. Strong, near-term action to cut
emissions of SLCPs, in conjunction with immediate and continuous reductions in
emissions of CO
2
, is the only way to stabilize global warming below 2
o
C. Accordingly,
California has signed a number of agreements to work together with other countries,
including China and Mexico, to support actions to fight climate change and cut air
pollution. Additionally, California is bringing together subnational jurisdictions under the
Subnational Global Climate Leadership Memorandum of Understanding (the “Under 2
MOU”), which commits signatories to take steps to reduce SLCP and CO
2
emissions
and meet the goal of keeping global average warming below the 2
o
C threshold by
reducing their GHG emissions to under 2 metric tons per capita, or 80–95 percent below
1990 levels, by 2050. To date, a total of 167 jurisdictions have signed or endorsed the
Under 2 MOU, collectively representing more than one billion people and nearly
$26 trillion in GDP, equivalent to 35 percent of the global economy.
5
As it implements
the actions identified in this SLCP Strategy and other related climate change planning
efforts, California will continue to share its successes and approach with others, to
expand action to address climate change and deliver local and global benefits for the
State.
5
http://under2mou.org/
17 March 14, 2017
I. Introduction: Showing the Way to 2
o
C
California must achieve deep reductions in short-lived climate pollutant (SLCP)
emissions by 2030 to help avoid the worst impacts of climate change and meet air
quality goals. Additionally, intensified, global action to reduce these emissions is the
only practical way to immediately slow global warming and is necessary to keep
warming below 2
o
C through at least 2050, which is a critical threshold to manage the
damaging effects of climate change. A broad scientific consensus has emerged, based
on extensive research, that a 2°C (3.6°F) increase in global average temperature above
pre-industrial levels poses severe risks to natural systems and human health and
well-being. This is an increase of only 1.1°C (2.0°F) above the present level. Even a
slight increase in global warming would lead to significant sea level rise, and the overall
impact from climate change would be substantially greater if global warming exceeds
2°C. Strong, near-term action to cut emissions of SLCPs, in conjunction with immediate
and continuous reductions in emissions of carbon dioxide (CO
2
), is the only way to
stabilize global warming below 2
o
C.
In December 2015, at the 21
st
Conference of Parties (COP21), 25,000 delegates from
196 countries gathered recognizing that “climate change represents an urgent and
potentially irreversible threat to human societies and the planet and thus requires the
widest possible cooperation by all countries, and their participation in an effective and
appropriate international response, with a view to accelerating the reduction of global
greenhouse gas emissions.” An agreement was reached to substantially reduce GHG
emissions with the aim of limiting a global temperature increase to below 2
o
C, mobilize
investments to support low-carbon development, and create a pathway for long-term
de-carbonization. Additionally, the agreement aims to strengthen the ability to deal with
the impacts of climate change.
Short-lived climate pollutants, including methane (CH
4
), black carbon (soot), and
fluorinated gases (F-gases, including hydrofluorocarbons, or HFCs), are among the
most harmful to both human health and global climate. They are powerful climate
forcers that remain in the atmosphere for a much shorter period of time than longer-
lived climate pollutants, including CO
2
, which is the primary driver of climate change.
Their relative climate forcing, when measured in terms of how they heat the
atmosphere, can be tens, hundreds, or even thousands of times greater than that of
CO
2
. Short-lived climate pollutants contribute about 40 percent to current
anthropogenic global radiative forcing, which is the primary forcing agent for observed
climate change.
6
,
7
,
8
,
9
,
10
6
Calculation based on IPCC AR5 WGI Chapter 8. https://www.ipcc.ch/pdf/assessment-
report/ar5/wg1/WG1AR5_Chapter08_FINAL.pdf
7
Ramanathan V, Xu Y. The Copenhagen Accord for limiting global warming: criteria, constraints, and
available avenues. Proceedings of the National Academy of Sciences of the United States of America.
2010;107 (18):8055–8062. [PMC free article]
8
IGSD (2013) Primer on Short-Lived Climate Pollutants, Institute for Governance and Sustainable
Development, February 2013. http://igsd.org/documents/PrimeronShort-
LivedClimatePollutantsFeb192013.pdf
18 March 14, 2017
California has taken significant steps to reduce SLCP emissions, especially black
carbon from transportation, methane from oil and gas operations and landfill emissions,
and HFC emissions from refrigerants, insulating foams, and aerosol propellants. Still,
more can and must be done to reduce emissions from these and other sources in the
State, including methane from waste management and dairies, black carbon from
off-road and non-mobile sources, and HFC emissions from refrigeration and air
conditioning systems.
The State is committed to further reducing SLCP emissions. SLCP emission reductions
are important, first of all, to continuing and maintaining the GHG emission reductions
called for by AB 32 and SB 32, and to ensuring emissions meet the statewide GHG
emission limits as codified. This SLCP Strategy is identified in the First Update to the
Climate Change Scoping Plan as one of the recommended actions to achieve additional
GHG emission reductions. Growing SLCP emissions (such as from fluorinated gases)
threaten to erode the State’s progress towards this limit; in other sectors (such as from
oil and gas and agriculture) continued emissions will put increased pressure on the
remainder of ARB’s regulatory structure to maintain overall emissions below the GHG
limit and to continue reductions. Conversely, addressing SLCP emissions will help to
ensure that the statewide GHG limits are maintained, and will fulfill AB 32’s mandate to
continue to seek the maximum technologically feasible and cost-effective reductions of
GHG emissions. Reducing these powerful climate-forcers early also produces a
compound-interest effect through which the effectiveness of future reductions are
magnified: those future reductions start from a baseline substantially lower than where
they would have started in the absence of aggressive early reduction efforts. The
Legislature directly recognized the critical role that SLCPs must play in the State’s
climate efforts with the passage of two bills: Senate Bill 605 (Lara, Chapter 523,
Statutes of 2014), which requires the Air Resources Board (ARB or Board) to develop a
strategy to reduce SLCP emissions; and Senate Bill 1383 (Lara, Chapter 395, Statutes
of 2016), which requires the Board to approve and begin implementation of the SLCP
Strategy by January 1, 2018, and sets 2030 reduction targets for SLCP emissions.
Significant reductions in SLCP emissions can be achieved globally using cost-effective
technologies and strategies, some of which have already been demonstrated effectively
in California. Over the past several decades, the State’s efforts in controlling these
harmful emissions have prevented thousands of premature deaths in California, saved
the State many tens of billions of dollars in energy and health costs, and have occurred
alongside strong economic growth throughout our diverse economy. Applying
9
Akbar, Sameer; Ebinger, Jane; Kleiman, Gary; Oguah, Samuel. 2013. Integration of short-lived climate
pollutants in World Bank activities: a report prepared at the request of the G8. Washington DC ; World
Bank. http://documents.worldbank.org/curated/en/2013/06/18119798/integration-short-lived-climate-
pollutants-world-bank-activities-report-prepared-request-g8
web.stanford.edu/group/efmh/jacobson/Articles/VIII/BCClimRespJGR0710.pdf
10
Molina M, Zaelke D, Sarma KM, Andersen SO, Ramanathan V, Kaniaru D. Reducing abrupt climate
change risk using the Montreal Protocol and other regulatory actions to complement cuts in CO2
emissions. Proceedings of the National Academy of Sciences of the United States of America.
2009;106(49):20616-20621. doi:10.1073/pnas.0902568106.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2791591/
19 March 14, 2017
California’s experiences to reduce SLCP emissions globally would help prevent millions
of premature deaths each year; boost agricultural productivity; limit disruption of historic
rainfall patterns; slow the melting of glaciers, snowpack, and sea ice; reduce sea level
rise; and provide trillions of dollars in economic benefits each year.
A. Significant Benefits from Accelerated Action to Cut SLCP Emissions
While reducing CO
2
emissions limits climate change over the long term, reducing
emissions of SLCPs will effectively slow the rate of climate change in the near-term.
Therefore, the best path forward is to emphasize parallel strategies for reducing SLCP
and CO
2
emissions.
11
,
12
Studies indicate that available technologies, if universally
adopted, can effectively reduce global methane emissions an estimated 40 percent and
black carbon an estimated 80 percent relative to a "reference" scenario by 2030.
13
,
14
Additionally, a new proposed global phase down of HFCs under the Montreal
Protocol that was adopted in October 2016 is expected to cut the production of HFCs by
up to 70 percent by 2030, and up to 85 percent by 2036 in developed countries
including the U.S.
15
,
16
Achieving this scale of global reductions would deliver significant climate benefits. It
would cut the expected rate of global warming in half by 2050, slowing global
temperature rise by about 0.6
o
C,
17
,
18
which would reduce the risk of dangerous climate
feedbacks such as accelerated Arctic melting and sea level rise.
19
It would also
11
Shoemaker, J K; Schrag, D P; Molina, M J; Ramanathan, V (2013) What Role for Short-Lived Climate
Pollutants in Mitigation Policy? Science 342 (6164) 1323-1324
12
Rogelj, J, Schaeffer M, Meinshausen M, Shindell D, Hare W, Klimont Z, Velders G, Amann M,
Schellnhuber HJ. 2014. Disentangling the effects of CO2 and short-lived climate forcer mitigation.
Proceedings of the National Academy of Sciences (PNAS).
http://www.pnas.org/cgi/doi/10.1073/pnas.1415631111
13
UNEP (2014) Time to Act (To Reduce Short-Lived Climate Pollutants), The Climate and Clean Air
Coalition to Reduce Short-Lived Climate Pollutants, United Nations Environment Programme, Second
Edition, May. http://www.unep.org/ccac/Publications/Publications/TimeToAct/tabid/133392/Default.aspx
14
UNEP and WMO (2011) Integrated Assessment of Black Carbon and Tropospheric Ozone, United
Nations Environment Programme and World Meteorological
Association. http://www.unep.org/dewa/Portals/67/pdf/BlackCarbon_report.pdf
15
UNEP (2016). United Nations Environment Programme (UNEP). Further Amendment of the Montreal
Protocol submitted by the Contact Group on HFCs. 14 October 2016.
http://www.unep.org/Documents.Multilingual/Default.asp?DocumentID=27086&ArticleID=36283&l=en
16
IGSD (2016) Institute for Governance and Sustainable Development (IGSD) “Nations Agree to Kigali
Amendment: Largest Near-Term Temperature Reduction from Single Agreement”, 15 October 2016.
http://www.igsd.org/nations-agree-to-kigali-amendment-largest-near-term-temperature-reduction-from-
single-agreement/.
17
Ramanathan V, Xu Y. The Copenhagen Accord for limiting global warming: criteria, constraints, and
available avenues. Proceedings of the National Academy of Sciences of the United States of America.
2010;107 (18):8055–8062. [PMC free article]
18
UNEP (2014) Time to Act (To Reduce Short-Lived Climate Pollutants), The Climate and Clean Air
Coalition to Reduce Short-Lived Climate Pollutants, United Nations Environment Programme, Second
Edition, May. http://www.unep.org/ccac/Publications/Publications/TimeToAct/tabid/133392/Default.aspx
19
UNEP and WMO (2011) Integrated Assessment of Black Carbon and Tropospheric Ozone, United
Nations Environment Programme and World Meteorological Association.
http://www.unep.org/dewa/Portals/67/pdf/BlackCarbon_report.pdf
20 March 14, 2017
increase the probability of staying below the 2
o
C threshold to more than 90 percent
through 2050.
20
,
21
The benefits could be even greater in the Arctic, which is especially vulnerable to black
carbon emissions and is warming twice as fast as the rest of the world.
22
Slowing
climate change impacts in the Arctic could be critically important for stabilizing climate
change and its impacts, as the Arctic is an important driver of sea level rise and weather
patterns throughout the Northern Hemisphere.
23
,
24
Reducing emissions of SLCPs can
slow down the rate of sea level rise by 24–50 percent this century, if efforts to reduce
emissions begin now. Mitigating emissions of both CO
2
and SLCPs can reduce the
projected sea level rise rate by 50–67 percent by 2100.
25
Deploying existing, cost-effective technologies to reduce SLCP emissions can also cut
global emissions of fine particulate matter (PM2.5) by an estimated 50 percent, oxides
of nitrogen (NO
x
) emissions by 35 percent, and carbon monoxide (CO) emissions by
60 percent.
26
If these measures were fully in place by 2030, an estimated 3.5 million
premature deaths and 53 million metric tons of crop losses could be avoided globally,
each year. The economic value of these climate, crop, and health benefits is estimated
to be about $5.9 trillion annually.
27
Most of these benefits would accrue in the
developing world and places where disproportionate climate impacts are already being
felt.
Many of the benefits of cutting SLCP emissions in California will accrue in the most
disadvantaged parts of the State, where pollution levels and their health impacts are
often highest, and where further economic development may be most needed. For
example:
Further cutting black carbon emissions from the transportation sector and
building a sustainable freight system would have health and economic benefits
20
Ramanathan, V. and Yangyang Xu (2010) The Copenhagen Accord for Limiting Global Warming:
Criteria, Constraints, and Available Avenues, Proceedings of the National Academies of Sciences 107
(18), pp.8055-8062. http://www.pnas.org/content/107/18/8055
21
Xu, Y., D. Zaelke, G. J. M. Velders, and V. Ramanathan (2013), The role of HFCs in mitigating 21st
century climate change, Atmos. Chem. Phys., 13(12), 6083–6089
22
Quinn et al (2008) Short-lived pollutants in the Arctic: Their impact and possible mitigation strategies,
Atmospheric Chemistry and Physics 8, 1723-1735. http://www.atmos-chem-phys.net/8/1723/2008/acp-8-
1723-2008.html
23
Francis, J. A. and S. J. Vavrus. 2012. Evidence linking Arctic amplification to extreme weather in mid-
latitudes. Geophysical Research Letters 39.
24
Screen, J. A. and I. Simmonds. 2013. Exploring links between Arctic amplification and mid-latitude
weather. Geophysical Research Letters 40(5):959-964.
25
Hu, A., Y. Xu, C. Tebaldi, W. M. Washington, and V. Ramanathan (2013), Mitigation of short-lived
climate pollutants slows sea-level rise Nature Climate Change 3(5), 1–5, doi:10.1038/nclimate1869
26
UNEP and WMO (2011) Integrated Assessment of Black Carbon and Tropospheric Ozone, United
Nations Environment Programme and World Meteorological Association.
http://www.unep.org/dewa/Portals/67/pdf/BlackCarbon_report.pdf
27
Shindell et al. (2012) Simultaneously Mitigating Near-Term Climate Change and Improving Human
Health and Food Security, Science 335, 183 (2012). http://www.sciencemag.org/content/335/6065/183
21 March 14, 2017
for communities in the East Bay, Southern California, and the Inland Empire
along freight corridors and near ports and rail yards where diesel particulate
matter concentrations are highest.
Investments to cut methane and black carbon emissions as part of an integrated
strategy to reduce emissions from agriculture and waste can provide important
benefits for the Central Valley and other agricultural communities. They can help
build an increasingly resilient and competitive agricultural sector by supporting
jobs and economic growth, healthy soils, and improved air quality, water quality,
and public health in those communities.
Switching to low-GWP refrigerants can also improve the energy efficiency of
refrigeration and air conditioning equipment, which can help to cut electricity bills
throughout the State.
B. Building on California’s Air Quality and Climate Leadership
California’s ongoing efforts to improve air quality and address climate change have
already led to important reductions in SLCP emissions, and they provide a strong
foundation to support further efforts to reduce emissions of these dangerous pollutants.
Black carbon: California has cut anthropogenic sources of black carbon
emissions by more than 90 percent since the 1960s. From 2000 to 2020,
California will have cut black carbon from mobile sources by 75 percent. These
efforts prevent an estimated 5,000 premature deaths in the State each year, and
deliver important climate benefits. If the world replicated this success, it would
slow global warming by an estimated 15 percent,
28
essentially offsetting one to
two decades’ worth of CO
2
emissions.
29
Methane: California has the nation's strongest standards for limiting methane
emissions from landfills, has offset protocols under our Cap-and-Trade Program
to encourage the reduction of methane emissions, and has rules under
development and being implemented to create a comprehensive approach to
limit methane leaks from the oil and gas production, processing, and storage
sector, and the natural gas pipeline system. These efforts are serving to keep
methane emissions fairly steady in the State.
HFCs: The State has regulations in place to reduce emissions from refrigerants,
motor vehicle air-conditioning, and consumer products that together are expected
to cut emissions of HFCs by 25 percent below otherwise projected levels in 2020.
Still, more remains to be done. California is home to some of the highest levels of air
pollution in the country, and although the State has substantially reduced particulate
matter and black carbon emissions from on-road transportation, vehicles still pollute the
28
Ramanathan et al (2013) Black Carbon and the Regional Climate of California, Report to the California
Air Resources Board, Contract 08-323, April 15. http://www.arb.ca.gov/research/single-
project.php?row_id=64841
29
Wallack, J. and Veerabhadran Ramanathan (2009) The Other Climate Changers: Why Black Carbon
and Ozone Also Matter, Foreign Affairs, September/October 2009, pp. 105-113.
https://www.foreignaffairs.com/articles/2009-09-01/other-climate-changers
22 March 14, 2017
air in our communities and harm the lungs of some of our most vulnerable populations.
Global methane emissions are responsible for about 20 percent of current global
warming,
30
and its emissions continue to increase. F-gases, specifically HFCs, are the
fastest growing source of GHG emissions in California and globally.
C. Purpose of SLCP Reduction Strategy
The State is committed to further reducing SLCP emissions. The 2014 Update to the
Climate Change Scoping Plan (2014 Scoping Plan Update) identified SLCPs as an
important aspect of a comprehensive approach to addressing climate change. In
September 2016, the Legislature passed and Governor Brown signed SB 32 (Pavley,
Chapter 249, Statutes of 2016), which codifies an earlier Executive Order, and
reinforces direction already in AB 32 by requiring statewide GHG emissions to be
reduced to 40 percent below 1990 emission levels by 2030. Specific to SLCP emission
reductions, Senate Bill 605 requires ARB to develop a plan to reduce emissions of
SLCPs, and Senate Bill 1383 requires the Board to approve and begin implementation
of the SLCP Strategy by January 1, 2018, and sets SLCP emission reduction targets for
2030 that are in-line with the 40 percent reductions called for in SB 32.
Senate Bill 605 (Appendix A), requires ARB to develop a comprehensive strategy, in
consultation with other State agencies and the air districts, to reduce emissions of
SLCPs in the State, including completing an inventory of SLCPs in the State, identifying
research gaps, identifying existing and potential new control measures to reduce
emissions, and prioritizing the development of new measures for SLCPs that offer co-
benefits.
Senate Bill 1383 (Appendix B) requires ARB to approve and begin implementing the
SLCP Strategy by 2018, codifies the statewide SLCP emission reduction targets that
were in earlier versions of the SLCP Strategy, provides specific direction for reductions
from dairy and livestock operations and from landfills by diverting organic materials,
requires actions to support in-State production and use of renewable natural gas, and
stipulates guidelines and analyses that will shape the implementation of this SLCP
Strategy.
ARB developed this final proposed SLCP Reduction Strategy (SLCP Strategy) pursuant
to SB 605 and SB 1383, in coordination with other State agencies and local air quality
management and air pollution control districts. The SLCP Strategy has been developed
with input from interested stakeholders in an open and public process and describes a
strategy for California to reduce emissions of SLCPs through 2030. It describes
ongoing and potential new measures to reduce SLCP emissions from all major sources
in the State, and describes current and future research needs for improving the SLCP
emission inventory and better understanding potential mitigation measures. California’s
30
Kirschke, S. et al. (2013) Three decades of global methane sources and sinks. Nature Geosci. 6, 813–
823. http://www.nature.com/ngeo/journal/v6/n10/full/ngeo1955.html?WT.ec_id=NGEO-201310
23 March 14, 2017
SLCP emission inventory
31
and current and future research needs are included in
Appendix C, and research efforts to evaluate potential mitigation measures for each
SLCP is included in Appendix D.
Measures included in this SLCP Strategy will be developed under future public
regulatory processes with the appropriate public process, economic analyses,
environmental analyses, and consideration of environmental justice. ARB's rulemaking
process includes extensive stakeholder input. California law and policy require a
careful, deliberative process when regulations are being developed, that includes
extensive review and analysis of economic and environmental impacts as required by
the Administrative Procedure Act (APA) and California Environmental Quality Act
(CEQA). SB 1383, and SB 605 also make clear that ARB is to carefully consider such
matters, including potential effects on compliance with state programs to reduce criteria
pollutants, potential interactions with other environmental challenges, the risk of leakage
(a reduction in GHG emissions within the State that is offset by an increase in out of
State GHG emissions), and impacts on disadvantaged communities.
D. Achieving Science-Based Targets
SB 1383 sets statewide SLCP emission reduction targets of 40 percent below 2013
levels by 2030 for methane and HFCs, and 50 percent below 2013 levels by 2030 for
anthropogenic black carbon emissions, codifying the proposed targets included in
earlier versions of this Strategy. For purposes of this SLCP Strategy, anthropogenic
black carbon emissions do not include forest-related sources (wildfires, prescribed
burning, and managed natural fires). The emission reductions associated with these
targets are translated into millions of metric tonnes of CO
2
-equivalent (MMTCO
2
e) in
Table 4.
31
Inventory methodology and detailed inventory tables available at:
http://www.arb.ca.gov/cc/inventory/slcp/slcp.htm
24 March 14, 2017
Table 4: California SLCP Emissions and Emission Reduction Target Levels
(MMTCO2e)*
2013
2030 BAU**
2030 Emission
Reduction Target
(percent reduction from
2013)
38
26
19 (50%)
118
117
71 (40%)
40
65
24 (40%)
*Using 20-year GWPs from the 4
th
Assessment report of the IPCC for methane and HFCs, and 5
th
Assessment report for black carbon (the first report to define a GWP for black carbon)
**Business As Usual (BAU) forecasted inventory includes reductions from implementation of current
regulations
The measures identified in this SLCP Strategy and their expected emission reductions
will feed into the update to the Climate Change Scoping Plan that is currently being
developed. The 2017 Scoping Plan Update will establish a broad framework for
meeting all of California's climate-related targets and will include an evaluation of all
proposed GHG reducing activities, for both short-lived and longer-lived pollutants.
Throughout this SLCP Strategy, there is an emphasis on early actions, often supported
by public investments and strong policy incentives. This approach is intended to
achieve earlier reductions (in the 2020 timeframe), bring projects online quickly, and
help scale sector-wide solutions while potential regulatory or other measures to reduce
SLCP emissions are developed. By supporting early action through investments and
commitments to overcome barriers, we can maximize benefits throughout California,
while minimizing the impact of future regulations on businesses in these sectors.
Together with California’s previous efforts to successfully reduce black carbon and other
SLCP emissions, implementing the measures identified in this SLCP Strategy to meet
these targets would put California on the path to meet the State's 2030 climate goals,
while delivering significant agricultural, air quality, economic, health, water, and other
climate co-benefits.
E. Coordinating Research Efforts Related to SLCPs
Many California State agencies sponsor climate-related research. State-sponsored
climate research, including research related to SLCPs, has been guided by the needs
identified in state laws, Executive Orders, and other policy documents, as well as the
best and latest science.
Since 2008, the Climate Action Team Research Working Group (CATRWG) has
provided a forum for State agencies to discuss and coordinate their proposed research
activities. The CATRWG also facilitates coordination with external groups including
academia, federal agencies, the international community, and private entities.
25 March 14, 2017
Integration and coordination with non-state sponsored research programs is important
to leverage State resources and to provide coherent and practical research results for
California.
To support these efforts, the CATRWG has created a catalog of relevant research
projects supported by the State since the early 2000s.
32
The catalog keeps State
agencies and interested stakeholders informed about the range of activities and the
status of individual projects. The catalog includes a number of projects related to the
impacts of SLCPs on regional climate in California, research underway to enhance
SLCP inventories, and evaluations of SLCP mitigation strategies.
In 2015, the CATRWG released a Climate Change Research Plan for California.
33
The
Plan synthesizes the knowledge gaps, and presents research priorities for the next
three to five years for policy-relevant, California-specific research. It includes research
needs related to the mitigation of SLCPs and specific needs to improve SLCP
inventories. The Plan outlines these research needs in order to inform the State’s
ongoing activities without duplicating federal research activities. This is an
unprecedented effort resulting in the first comprehensive climate change research plan
developed by any state. The CATRWG will update the Plan every other year, with
major revisions every four years. Research related to SLCPs will continue to be a
priority in these updates.
Future State-sponsored research will be guided by recommendations in the CATRWG
Research Plan, as well as other documents such as this SLCP Strategy. State
agencies will continue to leverage funding and avoid duplication of effort through
coordination in CATRWG meetings. State agencies that sponsor research will also
continue their individual efforts to align future research needs with input from
stakeholders, academic experts and other public and private research entities.
F. Process for Developing the SLCP Reduction Strategy
This SLCP Strategy was developed
with input from State and local
agencies, academic experts, a working
group of agricultural experts and
farmers convened by CDFA, and other
interested stakeholders in an open and
public process. ARB and State
agencies collaborated to identify
reduction measures for specific
sectors, including the dairy,
wastewater, and waste sectors. In
addition, ARB collaborated with the
32
California’s State-sponsored Research Catalog: http://cal-adapt.org/research/
33
Climate Change Research Plan for California (2015)
http://www.climatechange.ca.gov/climate_action_team/reports/CAT_research_plan_2015.pdf
26 March 14, 2017
local air districts to identify SLCP emission reduction measures that could be
implemented through district action, such as residential wood burning incentive
programs.
ARB staff released several drafts of the SLCP Strategy for public review:
A Concept Paper for the SLCP Strategy in May 2015;
A Draft SLCP Reduction Strategy in September 2015;
A Proposed SLCP Strategy in April 2016;
A Revised Proposed SLCP Strategy in November 2016 that incorporated specific
requirements from SB 1383; and
This final proposed SLCP Strategy in March 2017.
Ten public workshops were held to solicit public input on previous drafts of the report.
In addition, staff provided an update to the Board on the SLCP Strategy in May 2016.
ARB staff prepared a Revised Draft Environmental Analysis (Revised Draft EA) for the
Revised Proposed SLCP Strategy. The Revised Draft EA provided an analysis of the
potential environmental impacts associated with implementing the recommended
measures in the SLCP Strategy. The Revised Draft EA was circulated for a 45-day
public review and comment period from November 28, 2016, through January 17, 2017.
ARB staff prepared written responses to comments received on the Revised Draft EA
and prepared the Final Environmental Analysis (Final EA) for the Revised Proposed
SLCP Strategy, which includes minor revisions to the Revised Draft EA.
The final proposed SLCP Strategy, the Final EA, and written responses to comments
received on the Revised Draft EA were posted to ARB's SLCP website and will be
presented to the Board for consideration at a public hearing in March 2017.
27 March 14, 2017
II. California’s Approach to Reducing SLCP Emissions
The 2014 Scoping Plan Update described California’s approach to climate change as
one reliant on science and foundational research. The Update focused on: preserving
natural resources that provide for our economy and define our lifestyle in California,
fostering resilient economic growth throughout the State, improving public health, and
supporting economic, social and environmental justice. The State’s commitment to
addressing climate change and public health is born of necessity, but provides
tremendous opportunity to build competitiveness and resilience into our communities,
resources, and economy. We understand that steps we take to reduce emissions and
strengthen our State against the impacts of climate change provide economic
opportunities today, and untether our future potential from limits imposed by resource
constraints and pollution.
This approach continues to guide us as we focus on reducing emissions of SLCPs to
meet the targets in this SLCP Strategy, as well as other requirements in SB 1383 and
SB 605. Additionally, California’s approach to reducing SLCP emissions is framed by
the principles described below.
A. Prioritize Actions with Diverse Benefits
The direct benefits of cutting SLCP emissions will be immediately tangible, and can be
substantial. As part of an integrated strategy to not only reduce emissions of SLCPs,
but also to develop renewable sources of energy and strengthen the competitiveness
and resiliency of our agricultural, waste, and other sectors, they can deliver even
greater benefits, including:
Reduced asthma risk, hospitalization, premature death, and associated medical
costs from air pollution, especially in disadvantaged communities;
Reduced global and localized climate change impacts, including sea level rise
and disrupted precipitation patterns, and associated costs;
Reduced crop losses from air pollution;
Healthy soils that are more sustainable and resilient to climate change, sequester
GHGs, require less synthetic amendments, and improve water retention;
The creation of a new industry, mostly in rural parts of the State and the Central
Valley, around utilizing organic waste streams to generate renewable energy,
fuels, and compost—bringing billions in investment; and
Stronger agricultural and freight sectors that are well positioned to continue
competing globally and growing as a source of jobs and economic development
in California.
Clearly, there are a number of drivers and benefits to reducing SLCP emissions that
extend beyond mitigating the impacts of climate change. The measures identified in
this SLCP Strategy are intended to provide a wide array of climate, health, and
economic benefits throughout the State. As they are further developed and
implemented, a key focus will be to provide and maximize multiple benefits.
28 March 14, 2017
B. Put Organic Waste to Beneficial Use
California’s organic waste streams are responsible for half of the State’s methane
emissions and represent a valuable energy and soil-enhancing resource. Effectively
implementing the measures described in this SLCP Strategy will not only reduce
methane emissions but provide many other benefits as well, including cutting emissions
of CO
2
and boosting economic growth in agricultural and rural communities.
Building infrastructure to better manage organic waste streams could lead to billions of
dollars of investment and thousands of jobs in the State.
34
,
35
This infrastructure could
provide valuable new sources of renewable electricity or biogas, clean transportation
fuels, compost as well as other beneficial soil amendments, and other products.
Adopting state policies to promote biogas from organic waste would provide a strong
durable market signal to industry, agencies, and investors. In addition, this biogas can
help the State meet its 33 percent renewable mandate for hydrogen transportation fuel.
The State's new 50 percent renewable portfolio standard may drive renewable hydrogen
production even higher. SB 1383 requires CEC, CPUC, and ARB to develop policies to
support the development and use of in-state renewable natural gas to support dairy and
other biomethane project developments. It also requires CalRecycle, in consultation
with ARB, to adopt regulations to achieve the landfill organics disposal reduction goals,
assess progress towards meeting those goals, to conduct a product markets analysis
and identify project barriers to best use biomethane (pipeline and grid connections,
products, etc.), and to make recommendations for additional policies if warranted.
Collectively, products from organic
waste streams in California, and
potential environmental credits from
them, could represent a market
worth billions of dollars in California.
Utilizing clean technologies to put
organic waste streams to a
beneficial use can also serve to
improve regional air and water
quality and support economic growth
in agricultural and other
communities throughout the State.
For example, most dairies in
California currently store manure in
34
Kaffka et al (2011) Economic, Social, and Environmental Effects of Current and Near-term Biomass
Use in California, California Biomass Collaborative, University of California, Davis.
http://biomass.ucdavis.edu/publications/
35
Due to its large dairy industry, California likely represents more than its share of the estimated 11,000
potential new biogas systems that could be built in the U.S. and the associated $33 billion in capital
deployment, 275,000 short-term construction jobs, and 18,000 permanent jobs.
USDA, USEPA, USDOE (2014) Biogas Opportunities Roadmap: Voluntary Actions to Reduce Methane
Emissions and Increase Energy Independence.
http://www.usda.gov/oce/reports/energy/Biogas_Opportunities_Roadmap_8-1-14.pdf
29 March 14, 2017
uncovered lagoons and use lagoon water to fertilize on-site forage crops. This
approach to managing manure has helped to improve the efficiency of dairy farms and
milk production over the years. However, these lagoons also create one of the largest
sources of methane emissions in the State, and—when combined with imprecise or
improper land application of nutrients, water, and salts via flood irrigation of lagoon
effluent—can create adverse groundwater and nutrient management issues on farms.
Alternatively, manure can be managed in a way to reduce or avoid methane emissions
and open up opportunities for improving farm nutrient management activities. For
composting, utilizing clean technologies such as aerated static piles results in reduced
emissions of volatile organic compounds at the compost facilities, as well as GHG
emission reductions in the form of avoided landfill emissions and realization of co-
benefits such as increased soil health when the compost product is applied to soils.
In order to capture the entire potential value from California’s waste resources,
significant amounts of infrastructure remain to be built and markets must be fully
enabled. Barriers remain to achieving these wide-ranging economic and environmental
benefits, and must be addressed.
C. Identify Practical Solutions to Overcome Barriers
Maximizing the diverse benefits of putting organic waste streams to beneficial uses will
require overcoming barriers that have hindered such efforts in the past. Barriers affect
many parts of the supply and marketing chain, including feedstock, technology,
market/economics, permitting, technical feasibility, infrastructure, logistics, and user
behavior.
For example, inexpensive and abundant landfill capacity may make diverting organic
material relatively costly in some cases. Developing projects to generate renewable
energy and soil amendments from this waste stream will require additional investments
in clean technology and management practices, aligning economic incentives that
currently favor landfilling with the State’s objectives to put organic resources to better
use, streamlining various governmental and utility permitting processes, and quantifying
the co-benefits of using compost and incorporating that information into cross-media
regulatory decisions.
Technology or market barriers also remain in some sectors. Interconnecting distributed
sources of renewable energy onto the electricity grid, or biogas into pipelines, remains
an unnecessarily long and costly process in many cases. Utilizing biogas in a
conventional combustion engine to create electricity can exacerbate air quality problems
in many parts of the State, including the Central Valley and Southern California. Clean
engine and fuel options, or low-GWP refrigerants, are not available for all applications.
Markets for compost and soil amendments need to be built out and strengthened, which
would provide an important value stream for financing anaerobic digestion and compost
facilities. Additional support and time may be needed to strengthen existing and
emerging markets for renewable natural gas and fuels, soil amendments, and their
associated environmental attributes.
30 March 14, 2017
These barriers are not insurmountable, however. As California develops a SLCP
Strategy to reduce SLCP emissions and plans to meet its climate and air quality goals
for 2030, now is the time to solve them. This SLCP Strategy identifies strategies and
funding mechanisms to encourage the use of the cleanest technologies to advance the
State’s air quality, water quality, climate change, and other environmental objectives.
Solutions that address several environmental concerns—air quality, climate, and water
quality—and can be easily financed, are clear winners. SB 1383 requires ARB,
CalRecycle, and CDFA to work with stakeholders to identify and address technical,
market, regulatory and other challenges to putting California's waste resources,
including diverted landfill organics and dairy manure, to beneficial use.
Several existing programs already provide incentives to convert waste streams to
various forms of energy, which can be leveraged along with new efforts to increase the
share of renewable biogas used in California buildings, industry, and transportation. For
example, the LCFS and federal Renewable Fuel Standard provide strong economic
incentives to utilize organic waste resources for production of transportation fuels. At
current LCFS and RIN credit prices, anaerobic digestion projects that generate
transportation fuels at dairies, wastewater treatment plants, or elsewhere can be
self-sustaining (see Chapter VIII). In order to enable this market, however, barriers to
pipeline injection of biogas, among others, must be addressed. The CPUC has
authorized an incentive program, capped at $40 million in total, to offset half of
renewable natural gas interconnection costs of individual projects. AB 2313 (Williams,
Chapter 531, Statues of 2016) raised the incentives cap on dairy cluster projects to
$5 million and on other individual projects from $1.5 million to $3 million. State
agencies are already collaborating to overcome barriers to pipeline injection of biogas,
pursuant to the Governor’s call to make heating fuels cleaner,
36
and they will redouble
their efforts. This includes monitoring market progress pursuant to Assembly Bill 1900
(Gatto, Chapter 602, Statutes of 2012) and considering appropriate adjustments, as
needed. Additional research regarding constituents of concern in biomethane produced
from different feedstocks may lead to refinements in testing requirements for pipeline
injection and associated cost savings. Also, supplemental policy options to accelerate
biogas projects and access to the
pipeline will be considered, including
steps that utilities can take, options
to accommodate varying heat rates
of pipeline gas in certain instances,
and potential new policies like a
feed-in-tariff for renewable natural
gas.
SB 1383 places biomethane
development requirements on ARB,
CPUC, and CEC. By January 1,
2018, ARB is to establish energy
infrastructure development and
36
https://www.gov.ca.gov/news.php?id=18828
31 March 14, 2017
procurement policies needed to encourage dairy biomethane projects. CPUC is
required to direct gas companies to implement no fewer than five dairy biomethane pilot
projects to demonstrate interconnection to the common carrier pipeline system. On a
broader scale, SB 1383 requires CEC to develop recommendations for the development
and use of renewable gas as a part of its 2017 Integrated Energy Policy Report,
including identifying cost-effective strategies that are consistent with existing State
policies, including the Renewable Portfolio Standard, LCFS, Cap-and-Trade, the State's
waste diversion goals, and the SLCP Strategy. Based on CEC’s recommendations,
State agencies will strive to meet the State’s climate change, renewable energy, low
carbon fuel, and SLCP goals by considering and adopting policies and incentives to
significantly increase the sustainable production and use of renewable gas. CPUC will
consider additional policies to support the development and use in-State of renewable
gas that reduces SLCPs. These policies shall prioritize fuels with the greatest GHG
emission benefits, taking into account RNG carbon intensity and reductions in SLCP
emissions.
Building market certainty and value for compost and other soil amendment products will
also help to secure financing for projects to use organic waste and cut emissions of
SLCPs. Soil amendments from organic waste streams in California represent a
potential $200-400 million market in California, exceeding the likely value of energy
products from the resource.
37
Efforts to increase composting and anaerobic digestion—
and capture the diverse benefits from doing so—can be supported by efforts to promote
and account for the benefits of using compost, manure, and other soil amendments that
come from these processes. ARB, in cooperation with CalRecycle, has developed a
quantification methodology to estimate GHG emission reductions from composting and
anaerobic digestion projects funded through the Greenhouse Gas Reduction Fund
(GGRF). ARB is also coordinating with CDFA, CalRecycle, and other agencies
working on the Healthy Soils Initiative to identify additional research needs to inform the
science and accounting methods necessary to quantify the benefits of using compost
and other soil amendments and address any potential problems such as buildup of salts
or heavy metals in soil. Collaboration among state agencies, water districts, and local
governments will help quantify the benefits of using compost for urban storm water
management, soil remediation, water conservation, and other beneficial uses.
D. Invest in SLCP Emission Reductions and Communities
Achieving significant reductions in SLCPs will require substantial investments to provide
incentives and direct funding for priority sectors, sources, and technologies. Public
investments should be smart and strategic, to leverage private investment and
accelerate market transitions to cleaner technologies that foster significant system-wide
solutions to cut emissions of SLCPs, maximize resource recovery from organic waste
streams, and provide economic and health benefits in agricultural, disadvantaged, and
rural parts of the State. Examples may include targeted support to reduce emissions of
37
Informa Economics (2013) National Market Value of Anaerobic Digester Products, Prepared for the
Innovation Center for U.S. Dairy, February.
32 March 14, 2017
SLCPs and CO
2
through integrated strategies at dairies and in organic waste
management; throughout the freight system; in commercial refrigeration applications;
and from the management of woody waste materials in agricultural and other sectors.
Many of the sources and sectors responsible for SLCP emissions are concentrated in
communities with high levels of pollution or unemployment, which could especially
benefit from targeted investments to improve public health and boost economic growth.
These include SLCP emissions from sources of organic waste and dairies in the Central
Valley; ports and freight corridors in the East Bay, Los Angeles area and Inland Empire;
and oil production, landfills and other sources of SLCP emissions throughout the State.
Many communities in these areas, along with rural communities in the northern part of
the State and the Sierra, have some of the worst pollution burdens in the State, and
high rates of poverty and unemployment. They are also where many billions of dollars
in public and private investment will accrue in the coming years to reduce SLCP and
CO
2
emissions and strengthen our agricultural sector and build sustainable freight
systems.
Initial estimates regarding State support for infrastructure to meet the goals identified in
this SLCP Strategy is similar for both the waste sector and dairy sector. CalRecycle
and CDFA both estimate that direct State investments or incentives on the order of
$100 million per year for five years could significantly scale project development to cut
SLCP emissions associated with dairy manure and waste management. There could
also be some opportunity to optimize investments and co-locate infrastructure or utilize
existing infrastructure, including excess digestion capacity that exists at many
wastewater treatment plants, which could potentially reduce the level of incentive
funding needed to reach the targets outlined in this SLCP Strategy. Additional research
and working group efforts will focus on opportunities to optimize infrastructure rollout
and maximize benefit from any State investment.
The State will need to continue coordinating and utilizing funding sources, such as the
Greenhouse Gas Reduction Fund (Cap-and-Trade auction proceeds),
38
the Alternative
and Renewable Fuel and Vehicle Technology Program (AB 118), Electric Program
Investment Charge (EPIC) Program, Carl Moyer program, Air Quality Improvement
Program, and Proposition 39 to expand clean energy investments in California and
further reduce emissions of SLCPs and other GHGs. Additionally, programs including
the Bioenergy Feed-In Tariff, created by Senate Bill 1122 (Rubio, Chapter 612, Statutes
of 2012), Low Carbon Fuel Standard, Cap-and-Trade, Self-Generation Incentive
Program, Federal Renewable Fuel Standard, utility incentives pursuant to Assembly Bill
1900 (Gatto, Chapter 602, Statutes of 2012), and others provide important market
signals and potential revenue streams to support projects to reduce SLCP emissions.
These programs are described in more detail in Chapter VII.
38
AB 1532 (Pérez, Chapter 807), SB 535 (De León, Chapter 830), and SB 1018 (Senate Budget
Committee, Chapter 39) established the GHG Reduction Fund to receive Cap-and-Trade auction
proceeds.
33 March 14, 2017
Potential new funding mechanisms and incentive structures must also be considered.
These could include adjusting the waste disposal tipping fee and establishing a waste
generator fee to account for the full cost of managing organic materials and landfills,
state procurement contracts for renewable natural gas and other fuels in buildings or
vehicles as well as for compost and mulch products in landscaping and erosion control,
or labeling programs to recognize leading companies in the market place, including
freight haulers using clean technologies.
E. Advance the Science of SLCP Sources and Emissions
Data related to SLCPs and their sources is often less available or of lower quality than it
is for CO
2
. One reason is that energy-related emissions of CO
2
are often easier to
quantify than emissions of other GHGs, which may form through complex biological or
other processes where existing reporting guidelines and procedures may not apply.
There has also been less of a focus on collecting
additional data that could help to quantify GHG
emissions from some non-CO
2
sources.
This SLCP Strategy, including Appendices C
and D, describes several coordinated research
efforts under way and potential new ones to
provide a better understanding of methane
emissions from the natural gas system and
natural gas and oil supplied to California, dairy
operations, landfills, as well as various sources
of HFCs and black carbon emissions. Others
not identified here also may be considered in the future.
For example, methane emissions are emitted from a wide range of biological processes
and fugitive and area sources that make estimating emissions difficult. California’s
methane emission estimates are derived from a variety of surveys, government data
sources, growth assumptions and modeling methodologies. ARB staff is continuously
assessing ways to improve the methane inventory by incorporating the latest scientific
understanding of methane sources, through coordinated research with other agencies,
and by using the best available activity data. Additional research and improved data
sources will be needed to continue to refine the methane inventory and provide
California-specific activity data.
While improving data access and quality is not a prerequisite for many actions to reduce
emissions of SLCPs, it is nonetheless important for informing ongoing efforts to reduce
SLCP emissions and meet broader climate targets. Improved data and reliable GHG
measurements from landfills, dairies, and other more difficult-to-measure sources would
also be necessary before these sources could be potentially included in California’s
Cap-and-Trade Program. State agencies will continue to monitor technology
development and support continued research to improve the accuracy and reliability of
emissions accounting from these sources.
34 March 14, 2017
F. Need for Focused SLCP Programs
This SLCP Strategy outlines specific emission reduction measures that could reduce
California’s emissions of SLCPs. This reliance on direct regulations, in concert with the
existing greenhouse gas Cap-and-Trade Program, is consistent with California’s
approach on addressing climate change. California has already adopted several direct
measures that ensure GHG emission reductions are achieved in specific sectors,
including for SLCPs (for example, the Refrigerant Management Program that regulates
F-gas emissions). These types of requirements motivate focused change— such as
increased deployment of renewable energy (Renewable Portfolio Standard) or
transformation of transportation fuels (Low Carbon Fuel Standard)—which may be more
readily realized through direct measures than sole reliance on the Cap-and-Trade
Program.
The Cap-and-Trade Program covers combustion and process operations. These
emissions can be measured according to the accuracy requirements of the Mandatory
Greenhouse Gas Emissions Reporting Regulation, which includes accurate
quantification methodologies that allow for consistent carbon costs,
39
and the sources
align with those covered by federal reporting programs.
40
In contrast, most fugitive
emissions
41
(a category into which SLCP emissions generally fall) do not meet these
criteria.
42
They are frequently difficult to measure, measurements have high
uncertainties,
43
measurement methods are often difficult and less precise,
44
and carbon
costs are hard to assign with the same reliability as for combustion sources of CO
2
.
45
Because of these difficulties, and the importance of seeking SLCP-specific emission
reductions, which the Cap-and-Trade Program is not designed to produce; this SLCP
39
California Air Resources Board (2011) California’s Cap-and-Trade Program Final Statement of
Reasons, Response to Comment E-31, at pg. 425. available at
http://www.arb.ca.gov/regact/2010/capandtrade10/fsor.pdf.
40
Id., Response to Comment E-69, at pg. 448. available at
http://www.arb.ca.gov/regact/2010/capandtrade10/fsor.pdf.
41
Fugitives from certain oil and gas sources are an exception because, unlike other fugitive emissions,
they are possible to quantify with rigor.
42
ARB’s responses to comments in the 2011 Final Statement of Reasons for the Regulation and Western
Climate Initiative design documentation provide detailed rationale for the treatment of fugitive emissions
in specific sectors. For example, the quantification methods that are often used to quantify fugitive
emissions, including calibrated bagging, high volume sampling, and a default emissions factor, only
provide a snapshot of emissions rather than actual measurements of emissions from the source. See also
Western Climate Initiative, Inc. (2010) WCI Comments on the Proposed Mandatory Reporting of GHG
Emissions from Proposed Reporting for Oil and Gas Operations (Subpart W), at pg. 44. available at
http://www.westernclimateinitiative.org/document-archives/func-
download/258/chk,ab6041717dc1be9cd3430f4f7585cb8e/no_html,1/.
43
Western Climate Initiative, Inc. (2010) WCI Comments on the Proposed Mandatory Reporting of GHG
Emissions from Proposed Reporting for Oil and Gas Operations (Subpart W) at pg. 39. available at
http://www.westernclimateinitiative.org/document-archives/func-
download/258/chk,ab6041717dc1be9cd3430f4f7585cb8e/no_html,1/.
44
California Air Resources Board (2011) California’s Cap-and-Trade Program Final Statement of
Reasons, Response to Comment E-69, pg. 430 and 448. available at
http://www.arb.ca.gov/regact/2010/capandtrade10/fsor.pdf.
45
Id., Response to Comment E-31, at pg. 425. available at
http://www.arb.ca.gov/regact/2010/capandtrade10/fsor.pdf.
35 March 14, 2017
Strategy does not recommend expanding Cap-and-Trade Program coverage.
46
Instead,
the SLCP Strategy focuses on specific measures for SLCP-emitting sectors, consistent
with the approach ARB adopted while developing the AB 32 Scoping Plan and Cap-
and-Trade Program.
ARB notes that stakeholders have expressed divergent views on this basic approach as
it relates to animal agriculture. On one hand, the Animal Legal Defense Fund has
petitioned ARB to include emissions from that sector in the Cap-and-Trade Program.
On the other hand, representatives of many environmental justice and environmental
groups have argued that direct, sector-specific measures are preferable, as have
representatives of the dairy industry. This SLCP Strategy focuses on direct measures,
consistent with the necessity of reducing SLCP emissions from the dairy sector
specifically, and in-line with the design principles that underlie the State's climate
strategy and the Cap-and-Trade Regulation.
47
46
ARB considered this option in detail, however. Further discussion is available in the California
Environmental Quality Act (CEQA) appendix to this Strategy (Appendix E).
47
The Livestock Project Compliance Offset Protocol is one such more focused measure now in operation.
It contrasts with the wholesale coverage of the sector by the Cap-and-Trade Program that some
stakeholders suggest. This protocol, focused on encouraging sector-specific reductions, would not
operate if facilities in the sector had compliance obligations in the Program. The protocol balances the
need for clear quantification methodologies and regulatory program requirements and ensures any
credited voluntary GHG emission reductions meet the AB 32 criteria. The quantification methods included
in this protocol use conservative factors to ensure that only real emission reductions are eligible for
issuance of compliance offset credits.
36 March 14, 2017
III. Latest Understanding of Science on SLCPs
Climate change is already beginning to transform life on Earth. Around the globe,
seasons are shifting, temperatures are climbing and sea levels are rising. Continued
emissions of GHGs will cause further warming and changes in all components of the
climate system. Limiting climate change will require substantial and sustained
reductions of GHG emissions.
There is growing recognition within the scientific and policy communities that efforts to
address climate change should focus not only on reducing CO
2
emissions, but also on
reducing emissions of SLCPs. While reducing CO
2
emissions will limit total warming
over the long-term, reducing emissions of SLCPs will effectively slow the near-term rate
of climate change. Therefore, the best path
forward is to emphasize a coordinated
strategy for simultaneous emission
reductions for both SLCPs and CO
2,
48
,
49
which is needed to keep average warming
below 2
o
C this century.
Short-lived climate pollutants have
atmospheric lifetimes on the order of a few
days to a few decades, and their relative
climate forcing impacts, when measured in
terms of how they heat the atmosphere, can
be tens, hundreds, or even thousands of times greater than that of CO
2
. Short-lived
climate pollutants contribute about 40 percent to the current anthropogenic global
radiative forcing, which is the primary forcing agent for observed climate change.
50
,
51
,
52
,
53
,
54
48
Shoemaker, J K; Schrag, D P; Molina, M J; Ramanathan, V (2013) What Role for Short-Lived Climate
Pollutants in Mitigation Policy? Science 342 (6164) 1323-1324
49
Rogelj, J, Schaeffer M, Meinshausen M, Shindell D, Hare W, Klimont Z, Velders G, Amann M,
Schellnhuber HJ. 2014. Disentangling the effects of CO2 and short-lived climate forcer mitigation.
Proceedings of the National Academy of Sciences (PNAS).
http://www.pnas.org/cgi/doi/10.1073/pnas.1415631111
50
Calculation based on IPCC AR5 WGI Chapter 8. https://www.ipcc.ch/pdf/assessment-
report/ar5/wg1/WG1AR5_Chapter08_FINAL.pdf
51
Molina M, Zaelke D, Sarma KM, Andersen SO, Ramanathan V, Kaniaru D. (2009) Reducing abrupt
climate change risk using the Montreal Protocol and other regulatory actions to complement cuts in CO
2
emissions. Proceedings of the National Academy of Sciences of the United States of America.
2009;106(49):20616-20621. doi:10.1073/pnas.0902568106.
http://www.ncbi.nlm.nih.gov/pmc/articles/PMC2791591/
52
Ramanathan V, Xu Y. (2010) The Copenhagen Accord for limiting global warming: criteria, constraints,
and available avenues. Proceedings of the National Academy of Sciences of the United States of
America. 2010;107 (18):8055–8062. [PMC free article]
53
IGSD (2013) Primer on Short-Lived Climate Pollutants, Institute for Governance and Sustainable
Development, February 2013.
http://igsd.org/documents/PrimeronShort-
LivedClimatePollutantsFeb192013.pdf.
54
Akbar, Sameer; Ebinger, Jane; Kleiman, Gary; Oguah, Samuel. (2013) Integration of short-lived climate
37 March 14, 2017
Co-Benefits of Reducing SLCPs
In addition to limiting climate change
impacts already underway, SLCP
emission reductions would reduce
local air pollution and produce other
co-benefits. The benefits could be
even greater in the Arctic, which is
especially vulnerable to black carbon
emissions and is warming twice as
fast as the rest of the world.
55
This
would be critically important for
stabilizing climate change and its
impacts, as the Arctic is an important
driver of sea level rise and weather patterns throughout the Northern Hemisphere.
Climate change in the Arctic potentially impacts drought in California and extreme snow
and cold in the upper Midwest and New England, although such links have not been
definitively proven.
56
,
57
Accelerated warming in the Arctic could also lead to irreversible
climate “tipping points,” such as the release of vast quantities of CO
2
and methane from
melting permafrost.
58
In California, State and international action to reduce emissions of SLCPs can improve
air quality and reduce related health risks. Other benefits to California include reducing
damage to crops, reducing background ozone and particulate levels to help meet
federal air quality standards, and reducing disruption of historic rainfall patterns.
California is working with a set of national and subnational partners throughout the
world to fight air pollution and climate change, which will help deliver these benefits to
our State while providing significant benefits where emission reductions occur.
Climate Impact
Global mean sea level will continue to rise during the twenty-first century, and the rate
of sea level rise will exceed that observed during 1971 to 2010 due to increased ocean
pollutants in World Bank activities: a report prepared at the request of the G8. Washington DC; World
Bank. http://www-
wds.worldbank.org/external/default/WDSContentServer/WDSP/IB/2013/08/19/000333037_20130819113818/Re
ndered/PDF/804810WP0G80Re00Box0379805B00OUO090.pdf
55
Quinn et al (2008) Short-lived pollutants in the Arctic: Their impact and possible mitigation strategies,
Atmospheric Chemistry and Physics 8, 1723-1735. http://www.atmos-chem-phys.net/8/1723/2008/acp-8-
1723-2008.html
56
Francis, J. A. and S. J. Vavrus. 2012. Evidence linking Arctic amplification to extreme weather in mid-
latitudes. Geophysical Research Letters 39.
57
Screen, J. A. and I. Simmonds (2013) Exploring links between Arctic amplification and mid-latitude
weather. Geophysical Research Letters 40(5):959-964.
58
Ramanathan V, Xu Y. The Copenhagen Accord for limiting global warming: criteria, constraints, and
available avenues. Proceedings of the National Academy of Sciences of the United States of America.
2010;107 (18):8055–8062. [PMC free article].
38 March 14, 2017
warming and increased loss of mass from glaciers and ice sheets.
59
A recent study
raises the possibility of a more rapid rate of sea level rise in this century than forecast
by the U.N.’s Intergovernmental Panel on Climate Change (IPCC).
60
The authors
conclude that 2
o
C global warming above the preindustrial level would spur ice shelf
melt sufficient to cause a sea level rise of several meters. Sea level rise is an important
impact of climate change on California due to the long coastline and large population
that lives near coastal waters. Mitigating SLCP emissions can have significant benefits
for slowing sea level rise, reducing the rate by 24-50 percent by 2100, if it begins now.
Mitigating emissions of both CO
2
and SLCPs can reduce the projected rate of sea level
rise by 50–67 percent by 2100.
61
Climate warming has intensified the recent drought in the southwestern U.S. as part of a
trend toward enhanced drought that is projected to intensify through this century.
62
California droughts may be increasingly intensified due to declining availability of
groundwater reserves. In the Central Valley, the current drought has cost California
agriculture about $2.7 billion and more than 20,000 jobs in 2015, and agriculture is
expected to face more frequent drought.
63
The current California drought highlights the
critical need for developing drought resilience, even if wet conditions mitigate the
current drought.
64
,
65
Achieving Climate Stabilization
Scientific research indicates that an increase in the global average temperature of 2°C
(3.6°F) above pre-industrial levels, which is only 1.1°C (2.0°F) above present levels,
poses severe risks to natural systems and human health and well-being. Increased
climate extremes, already apparent at present day climate warming (~0.9°C), will be
59
IPCC, 2013: Summary for Policymakers. In: Climate Change 2013: The Physical Science Basis.
Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on
Climate Change [Stocker, T.F., D. Qin, G.-K. Plattner, M. Tignor, S.K. Allen, J. Boschung, A. Nauels, Y.
Xia, V. Bex and P.M. Midgley (eds.)]. Cambridge University Press, Cambridge, United Kingdom and New
York, NY, USA. http://www.climatechange2013.org/images/report/WG1AR5_SPM_FINAL.pdf.
60
Hansen, J., Sato, M., Hearty, P., Ruedy, R., Kelley, M., Masson-Delmotte, V., Russell, G., Tselioudis,
G., Cao, J., Rignot, E., Velicogna, I., Kandiano, E., von Schuckmann, K., Kharecha, P., Legrande, A. N.,
Bauer, M., and Lo, K.-W.(2015) Ice melt, sea level rise and superstorms: evidence from paleoclimate
data, climate modeling, and modern observations that 2 °C global warming is highly dangerous, Atmos.
Chem. Phys. Discuss., 15, 20059-20179, doi:10.5194/acpd-15-20059-2015, 2015. http://www.atmos-
chem-phys-discuss.net/15/20059/2015/acpd-15-20059-2015.html
61
Hu, A., Y. Xu, C. Tebaldi, W. M. Washington, and V. Ramanathan (2013), Mitigation of short-lived
climate pollutants slows sea-level rise Nature Climate Change 3(5), 1–5, doi:10.1038/nclimate1869
62
Cook, B. I., T. R. Ault, and J. E. Smerdon (2015), Unprecedented 21st century drought risk in the
American Southwest and Central Plains, Science Advances, 1(1), e1400082,
doi:10.1126/sciadv.1400082.
63
Economic Analysis of the 2015 Drought for California
Agriculture. https://watershed.ucdavis.edu/droughtimpacts
64
Noah S. Diffenbaugh, N.S., D.L. Swain, and D. Touma (2015) Anthropogenic warming has increased
drought risk in California PNAS 2015 112 (13) 3931-3936; published ahead of print March 2, 2015,
doi:10.1073/pnas.1422385112. http://www.pnas.org/content/112/13/3931.abstract
65
A.P. Williams et al. (2015) Contribution of anthropogenic warming to California drought during 2012–
2014. Geophysical Research Letters, 2015 DOI: 10.1002/2015GL064924
39 March 14, 2017
more severe. Studies indicate that available technologies, if universally adopted, can
effectively reduce global methane emissions an estimated 40 percent and black carbon
an estimated 80 percent relative to a "reference" scenario by 2030".
66
,
67
Additionally, a
new proposed global phase down of HFCs under the Montreal Protocol that was
adopted in October 2016, is expected to cut the production of HFCs by up to 70 percent
by 2030, and up to 85 percent by 2036 in developed countries including the
U.S.
68
,
69
Achieving this scale of global reductions would deliver significant climate
benefits. It would cut the expected rate of global warming in half by 2050, slowing
global temperature rise by about 0.6
o
C,
70
,
71
which would reduce the risk of dangerous
climate feedbacks such as accelerated Arctic melting and sea level rise.
72
It would also
increase the probability of staying below the 2
o
C threshold to more than 90 percent
through 2050.
73
,
74
Global Warming Potential
The IPCC developed the concept of global warming potential (GWP) as an index to
evaluate the climate impacts of different GHGs, including SLCPs. This metric provides
a comparison of the ability of each GHG to trap heat in the atmosphere relative to CO
2
over a specified time horizon. Global warming potentials account for the lifetime of
different GHGs in the atmosphere, and the amount of energy they absorb on a
per-kilogram basis, relative to CO
2
, to represent the relative climate forcing of a kilogram
of emissions when averaged over a time period of interest (for example, 20 years or
10 years). Current practice in most of the world for developing GHG emission
inventories, including California's inventory, is to use GWP values from the
66
UNEP (2014) Time to Act (To Reduce Short-Lived Climate Pollutants), The Climate and Clean Air
Coalition to Reduce Short-Lived Climate Pollutants, United Nations Environment Programme, Second
Edition, May. http://www.unep.org/ccac/Publications/Publications/TimeToAct/tabid/133392/Default.aspx
67
UNEP and WMO (2011) Integrated Assessment of Black Carbon and Tropospheric Ozone, United
Nations Environment Programme and World Meteorological
68
UNEP (2016). United Nations Environment Programme (UNEP). Further Amendment of the Montreal
Protocol submitted by the Contact Group on HFCs. 14 October 2016.
http://www.unep.org/Documents.Multilingual/Default.asp?DocumentID=27086&ArticleID=36283&l=en
69
IGSD (2016) Institute for Governance and Sustainable Development (IGSD) “Nations Agree to Kigali
Amendment: Largest Near-Term Temperature Reduction from Single Agreement”, 15 October 2016.
http://www.igsd.org/nations-agree-to-kigali-amendment-largest-near-term-temperature-reduction-from-
single-agreement/.
70
Ramanathan V, Xu Y. The Copenhagen Accord for limiting global warming: criteria, constraints, and
available avenues. Proceedings of the National Academy of Sciences of the United States of America.
2010;107 (18):8055–8062. [PMC free article]
71
UNEP (2014) Time to Act (To Reduce Short-Lived Climate Pollutants), The Climate and Clean Air
Coalition to Reduce Short-Lived Climate Pollutants, United Nations Environment Programme, Second
Edition, May. http://www.unep.org/ccac/Publications/Publications/TimeToAct/tabid/133392/Default.aspx
72
UNEP and WMO (2011) Integrated Assessment of Black Carbon and Tropospheric Ozone, United
Nations Environment Programme and World Meteorological Association.
http://www.unep.org/dewa/Portals/67/pdf/BlackCarbon_report.pdf
73
Ramanathan, V. and Yangyang Xu (2010) The Copenhagen Accord for Limiting Global Warming:
Criteria, Constraints, and Available Avenues, Proceedings of the National Academies of Sciences 107
(18), pp.8055-8062. http://www.pnas.org/content/107/18/8055
74
Xu, Y., D. Zaelke, G. J. M. Velders, and V. Ramanathan (2013), The role of HFCs in mitigating 21st
century climate change, Atmos. Chem. Phys., 13(12), 6083–6089
40 March 14, 2017
4
th
Assessment Report of the IPCC (AR4), which was released in 2007. For the first
time, GWP estimates for black carbon are reported in the 5
th
Assessment Report of the
IPCC (AR5), which includes the independent scientific assessment of black carbon
radiative forcing published by Bond et al.
75
This SLCP Strategy uses AR4 values for
methane and HFCs, but AR5 for black carbon.
Considering ways of comparing the contributions of different climate pollutants to
climate change has been raised in the IPCC AR5. The report focuses the discussion on
the more well-known GWP and Global Temperature change Potential (GTP), though
other concepts are also briefly discussed. The GTP is defined as the change in global
mean surface temperature at a chosen point in time in response to an emission pulse,
relative to that of CO
2
. The Norwegian Environment Agency has recently performed an
integrated assessment of climate, health and environmental effects of Norwegian
emissions of SLCPs, and proposed measures for reducing such effects by 2030.
76
Specifically, they used the “GTP10, Norway”, a global temperature change potential
calculated ten years after the emission occurred in Norway, which they identify as the
most practically appropriate metric for analyzing measures for Norwegian emissions of
SLCPs in the short term. Overall, there is not one, single metric that describes the
comparative climate effects of various short-lived and long-lived climate pollutants
perfectly. The use of GWPs with a time horizon of 20 years better captures the
importance of the SLCPs and gives a better perspective on the speed at which SLCP
emission controls will impact the atmosphere relative to CO
2
emission controls. Thus,
the emission estimates presented later in this report are calculated using 20-year GWP.
Table 5 illustrates the lifetime and 20-year GWP for each SLCP.
Table 5: Global Warming Potential for SLCPs
1
Pollutant
Lifetime (years)
20-year GWP
Carbon dioxide
~100
2
1
Methane
12
72
F-Gases
(Hydrofluorocarbons)
1.4 – 52
437 – 6350
Black carbon
Days to weeks
3,200
1
All AR4 except black carbon which uses AR5 (the first report to define a GWP for
black carbon)
2
CO
2
has a variable atmospheric lifetime and cannot be readily approximated as a single
number
75
Bond, T. C., S. J. Doherty, D. W. Fahey, et al. (2013) “Bounding the role of black carbon in the climate
system: A scientific assessment.” Journal of Geophysical Research: Atmospheres doi:10.1002/jgrd
.50171. http://onlinelibrary.wiley.com/doi/10.1002/jgrd.50171/pdf
76
Norwegian Environment Agency, Summary of proposed action plan for Norwegian emissions of short
lived climate forcers, report M135/2014;
http://www.miljodirektoratet.no/Documents/publikasjoner/M135/M135.pdf
41 March 14, 2017
The following sections describe the major SLCPs. An inventory of sources and
emissions, and a discussion of current and proposed new control measures are
included in other portions of this report.
A. Black Carbon
Airborne particulate matter (PM) varies in its composition and plays a significant role in
human health and the climate system. Particulate matter is emitted from a variety of
natural processes and human activities, and tends to remain in the air for only a few
days to about a week, resulting in extreme spatial and temporal variability. Among
different types of particles, carbonaceous particles (those that contain organic and black
carbon) are particularly important because of their abundance in the atmosphere. With
respect to climate impact, black carbon is the principal absorber of visible solar radiation
in the atmosphere while organic carbon is often described as a light-reflecting
compound.
Black carbon is emitted from burning fuels such as coal, diesel, and biomass, as well as
from various forms of non-fuel biomass combustion (destruction of excess woody
wastes, wildfires, etc.). Black carbon contributes to climate change both directly by
absorbing sunlight and indirectly by depositing on snow and by interacting with clouds
and affecting cloud formation. In addition to its climate and health impacts, black
carbon disrupts cloud formation, precipitation patterns, water storage in snowpack and
glaciers, and agricultural productivity.
Scientists have known for some time that sources that emit black carbon also emit other
short-lived particles that may either cool or warm the atmosphere. Lighter colored
particles, for example, tend to reflect rather than absorb solar radiation and so have a
cooling rather than warming impact. Until recently, it had been thought that the impact
of lighter colored and reflecting organic carbon from combustion sources largely offset
the warming impact of black carbon from this source. However, new studies have
suggested that certain fractions of organic carbon known as “brown carbon” could be a
stronger absorber of solar radiation than previously understood.
77
,
78
The warming effect
of brown carbon may offset the cooling impact of other organic carbon particles; hence,
quantification of that absorption is necessary so that climate models can evaluate the
net climate effect of organic carbon.
To help characterize and differentiate sources of brown carbon from black carbon and
understand their climate impact in California, a current ARB-funded research project is
applying advanced measurement methodology along with regional and global climate
modeling simulations to characterize the extent to which brown carbon contributes to
77
Jacobson, M. Z. (2014), Effects of biomass burning on climate, accounting for heat and moisture fluxes,
black and brown carbon, and cloud absorption effects, J. Geophys. Res. Atmos., 119, 8980–9002,
doi:10.1002/2014JD021861 http://onlinelibrary.wiley.com/doi/10.1002/2014JD021861/pdf
78
Kodros, J. K., Scott, C. E., Farina, S. C., Lee, Y. H., L'Orange, C., Volckens, J., and Pierce, J. R.:
Uncertainties in global aerosols and climate effects due to biofuel emissions, Atmos. Chem. Phys., 15,
8577-8596, doi:10.5194/acp-15-8577-2015, 2015. http://www.atmos-chem-phys.net/15/8577/2015/acp-
15-8577-2015.pdf
42 March 14, 2017
climate forcing in California. This project will improve our understanding of the
fundamental processes that dominate brown carbon formation, and help to determine
the potential climate benefit of mitigating sources of brown carbon emissions in
California.
B. Methane
Methane is the principal component of natural gas and is also produced biologically
under anaerobic conditions in ruminants (animals with a four-part stomach, including
cattle and sheep), landfills, and waste handling. Atmospheric methane concentrations
have been increasing as a result of human activities related to agriculture, fossil fuel
extraction and distribution, and waste generation and processing. The atmospheric
lifetime of methane is about 12 years. It is well-mixed within the atmosphere, and like
other GHGs, warms the atmosphere by blocking infrared radiation (heat) that is re-
emitted from the earth’s surface from reaching space. Almost all of methane’s impact
occurs within the first two decades after it is emitted.
Methane is responsible for about 20 percent of current global warming,
79
and methane
emissions continue to increase globally. There is particular concern among scientists
that continued climate warming may cause massive releases of methane from thawing
arctic permafrost, and dissolve frozen methane clathrate deposits trapped within
shallow ocean sea floors.
A recent study, which examines the interaction of methane with other atmospheric
gases, indicates methane emissions may have even greater climate change impacts
than previously understood.
80
In the AR5 report, when all the feedbacks are included,
the GWP for methane was increased, from 25 to 28 over a 100-year timespan and from
72 to 84 over a 20-year timespan. However, for consistency with reporting
requirements under the United Nations Framework Convention on Climate Change,
ARB is using GWP values from the AR4.
Methane also contributes to global background levels of ozone in the lower atmosphere
(troposphere). Photo-oxidation of both methane and carbon monoxide lead to net
production of global background levels of ozone. Ozone itself is a powerful SLCP as
well as a regional ground level air pollutant. Tropospheric ozone is not emitted directly
into the atmosphere, but rather formed by photochemical reactions. Its average
atmospheric lifetime of a few weeks produces a global distribution highly variable by
season, altitude, and location. The radiative forcing of tropospheric ozone is primarily
attributed to emissions of methane, but also to carbon monoxide, volatile organics, and
nitrogen oxides that eventually form ozone.
79
Kirschke, S. et al. (2013) Three decades of global methane sources and sinks. Nature Geosci. 6, 813–
823. http://www.nature.com/ngeo/journal/v6/n10/full/ngeo1955.html?WT.ec_id=NGEO-201310
80
Holmes, C. D., M. J. Prather, O. A. Sovde, and G. Myhre. 2013. “Future methane, hydroxyl, and their
uncertainties: Key climate and emission parameters for future predictions.” Atmospheric Chemistry and
Physics 13: 285–302. http://www.atmos-chem-phys.net/13/285/2013/acp-13-285-2013.pd
43 March 14, 2017
Ozone negatively impacts human health, and can lead to asthma attacks,
hospitalizations, and even premature death. It impairs the ability of plants to absorb
CO
2
, thereby suppressing crop yields and harming ecosystems. Ozone also affects
evaporation rates, cloud formation, and precipitation levels. In addition to the direct
climate benefits of cutting methane emissions, it can also reduce global background
levels of ozone pollution and provide additional climate, health, and other
benefits.
81
,
82
,
83
Regional ozone concentrations reflect contributions from both ozone formed from
criteria pollutant emissions (NO
X
and volatile organic compounds [VOCs]) on a regional
scale, and ozone transported on hemispheric scales (global background levels of
ozone). Due to its low reactivity, methane emissions do not affect regional scale ozone
production that occurs over hours to days. However, regional methane emissions which
are fairly well-mixed in the atmosphere contribute to the global abundance of methane,
which in turn contributes to global background levels of ozone. About two-thirds of the
rise in global levels of tropospheric background ozone can be attributed to methane
emissions. Studies have also shown that the global background ozone concentrations
can approach 40 parts per billion and have been increasing in recent years. Increases
in background ozone make it harder to attain the health-based ambient air quality
standards set by U.S. EPA and California.
C. Fluorinated Gases (Hydrofluorocarbons)
Hydrofluorocarbons (HFCs) are synthetic gases used in refrigeration, air conditioning,
insulating foams, solvents, aerosol products, and fire protection. They are primarily
produced for use as substitutes for ozone-depleting substances (ODS), including
chlorofluorocarbons (CFCs) and hydrochlorofluorocarbons (HCFCs), which are being
phased out under the Montreal Protocol. Currently, HFCs are a small fraction of the
total climate forcing, but they are the fastest growing source of GHG emissions in
California and globally, primarily driven by the increased demand for non-ODS
refrigeration and air conditioning.
HFCs vary significantly in their ability to influence climate. Their differing ability is
mostly due to differences in their atmospheric lifetimes, which determine how much they
81
Fiore, A. M., J. J. West, L. W. Horowitz, V. Naik, and M. D. Schwarzkopf (2008) Characterizing the
tropospheric ozone response to methane emission controls and the benefits to climate and air quality, J.
Geophys. Res., 113, D08307, doi:10.1029/2007JD009162.
82
West, J. J., A. M. Fiore, L. W. Horowitz, and D. L. Mauzerall (2006), Global health benefits of mitigating
ozone pollution with methane emission controls, Proc. Natl. Acad. Sci. U.S.A., 103, 3988–3993.
83
Fiore, A. M., F. J. Dentener, O. Wild, C. Cuvelier, M. G. Schultz, P. Hess, C. Textor, M. Schulz, R. M.
Doherty, L. W. Horowitz, I. A. MacKenzie, M. G. Sanderson, D. Shindell, D. S. Stevenson, S. Szopa, R.
Van Dingenen, G. Zeng, C. Atherton, D. J. Bergmann, I. Bey, G. Carmichael, W. J. Collins, B. Duncan, G.
Faluvegi, G. Folberth, M. Gauss, S. Gong, D. Hauglustaine, T. Holloway, I. S. A. Isaksen, D. Jacob, J. E.
Jonson, J. W. Kaminski, T. J. Keating, A. Lupu, E. Marmer, V. Montanaro, R. J. Park, G. Pitari, K. J.
Pringle, J. A. Pyle, S. Schroeder, M. G. Vivanco, P. Wind, G. Wojcik, S. Wu, and A. Zuber (2009),
Multimodel estimates of intercontinental source-receptor relationships for ozone pollution, J. Geophys.
Res., 114, D04301, doi:10.1029/2008JD010816.
44 March 14, 2017
accumulate in the atmosphere. The mix of HFCs in current use, weighted by usage
(tonnage), has an average atmospheric lifetime of 15 years. HFCs are also potent
GHGs, with a warming effect hundreds to thousands of times more powerful than CO
2.
The average 100-year GWP of the current mix of HFCs being used is about 1700, and
the average 20-year GWP is about 3800. The major concern with respect to HFCs is
that their contribution to climate forcing is expected to increase rapidly in the future as
they continue to replace ozone depleting substances (ODS), such that they will become
very significant contributors. Studies indicate that a lack of action to prevent the growth
of HFCs would greatly undermine efforts to address climate change. A recent study
concluded that replacing high-GWP HFCs with low-GWP alternatives could avoid 0.1°C
of warming by 2050 and warming of up to 0.5°C by 2100,
84
offering one of the most
cost-effective climate mitigation strategies available.
The successful phase-out of CFCs and the ongoing phase-out of HCFCs have made
the Montreal Protocol an effective climate treaty.
85
,
86
Between 1990 and 2010 the
Montreal Protocol reduced CO
2
e emissions nearly twenty times more than the initial
commitment period of the Kyoto Protocol.
87
Although HFCs have contributed a
miniscule amount of historical climate forcing, they are projected to increase
significantly in the absence of control policies. Hence, a global phase down of HFCs is
necessary to slow their effect on climate change. International, national, and state
efforts to reduce emissions of HFCs are discussed in more detail in Chapter VI.
84
Xu Y., Zaelke D., Velders G. J. M., & Ramanathan V. (2013) The role of HFCs in mitigating 21
st
century
climate change , ATMOS. CHEM. PHYS. 13:6083-608.
85
Velders G. J. M. et al. (2007) The importance of the Montreal Protocol in protecting climate, Proc. Nat’l.
Acad. Sci. USA 104:4814.
86
Wu, Y., L.M. Polvani and R. Seager, (2013): The Importance of the Montreal Protocol in Protecting the
Earth's Hydroclimate. J. Climate, 26, DOI: 10.1175/JCLI-D-12-00675.1,
http://www.ldeo.columbia.edu/res/div/ocp/glodech/PDFS/Wu_etal_O3_2013.pdf
87
UNEP (2012) The Montreal Protocol and the Green Economy: Assessing the contributions and co-
benefits of a Multilateral Environmental Agreement.
45 March 14, 2017
IV. Reducing Anthropogenic Black Carbon Emissions
Black carbon is the light-absorbing component of fine particulate matter (PM) produced
during incomplete combustion of fuels. Black carbon does not account for the warming
effects of brown carbon. The lifetime of black carbon is very short, from days to weeks,
compared to other SLCPs, which may remain in the atmosphere for a few decades.
California has done more than any other jurisdiction in the world to reduce PM and
black carbon emissions. As a result, ambient levels of black carbon in California are
now 90 percent lower than in the early 1960s, despite the use of diesel fuel more than
tripling over the same time period.
88
If the rest of the world achieved similar reductions,
it could substantially improve health and slow global warming. California’s actions can
serve as a blueprint for other jurisdictions to reduce SLCP emissions and improve
public health. Existing programs will continue to reduce black carbon emissions. For
example, complying with federal air quality standards and reducing localized health risk
will require substantial reductions in smog-forming and PM emissions from mobile
sources and other source categories.
California’s major anthropogenic sources of black carbon include off-road
transportation, on-road transportation, residential wood burning, fuel combustion, and
industrial processes (Figure 1). The fuel combustion and industrial source categories
include a variety of stationary and portable equipment such as boilers, turbines, and
steam generators, as well as process emissions from industrial operations, such as
cement and asphalt production and pulp and paper mills. Sources in the
miscellaneous category include dust, waste disposal, unplanned structure and car
fires, residential natural gas combustion, and non-agricultural open burning (mostly
residential green waste burning).
Figure 1: California 2013 Anthropogenic Black Carbon Emission
Sources*
*Using 20-year GWP
Wildfire is the largest source of black carbon in California. Prescribed fires and
managed natural fires also emit black carbon, but are critical tools for forest managers.
88
V. Ramanathan et al. 2013. Black Carbon and the Regional Climate of California. Report to the
California Air Resources Board No. 08-323. http://www.arb.ca.gov/research/apr/past/08-323.pdf
46 March 14, 2017
However, since the legislative direction and intent of SB 1383 is to include only
anthropogenic, non-forest sources of black carbon in the target, and in light of
continued state research and policy development occurring in this area, a target for
forest-derived black carbon emission reductions is not included in this SLCP Strategy.
For reference, estimates for 10-year annual average black carbon emissions from fires
that occurred in forests and other lands are provided in Table 6. Emissions from fires
in forests and other lands vary dramatically from year-to-year, and these inventories
contain higher uncertainty
89
than the anthropogenic sources in Figure 1.
Table 6: 10-Year Average California Black Carbon Emissions: Wild and
Prescribed Fire
Source
10-Year Average Emissions
(MMTCO2e)*
Prescribed Burning
3.6
Wildfire
86.7
*Using 20-year GWP
In general, forests are burning at increasing rates and at increasing levels of
severity.
90
,
91
,
92
This trend raises concern over the long-term resilience of these forests
and ability to sequester carbon, mitigate climate change, and provide resource
amenities.
93
Many studies have demonstrated net benefits for fuel treatments and
forest management activities designed to reduce both fire spread and fire severity at
the experimental unit or stand level, both in modeled and real world
scenarios.
94
,
95
,
96
,
97
,
98
,
99
,
100
,
101
,
102
,
103
,
104
Fuel treatments are key elements of strategies
89
California Air Resources Board 2015 Edition of California’s Black Carbon Emission Inventory.
https://www.arb.ca.gov/cc/inventory/slcp/doc/bc_inventory_tsd_20160411.pdf
90
Hurteau, M. D., Westerling, A. L., Wiedinmyer, C. and Bryant, B. P. 2014. Projected effects of climate and
development on California wildfire emissions through 2100. Environmental Science & Technology, 48(4), pp.2298-
2304.
91
Dennison, P.E., Brewer, S.C., Arnold, J.D. and Moritz, M.A. (2014) Large wildfire trends in the western United
States, 1984-2011. Geophysical Research Letters 41: 2928-2933. doi:10.1002/2014GL059576.
92
Miller, J.D., Safford, H.D., Crimmins, M. and Thode, A.E. (2009) Quantitative evidence for increasing forest fire
severity in the Sierra Nevada and Southern Cascade mountains, California and Nevada, USA. Ecosystems 12: 16-
32. doi:10.1007/s10021-008-9201-9.
93
North, M. P. and Hurteau, M. D., 2011. High-severity wildfire effects on carbon stocks and emissions in fuels
treated and untreated forest. Forest Ecology and Management, 261(6), pp.1115-1120.
94
Finney, M. A., McHugh, C. W., & Grenfell, I. C. (2005). Stand-and landscape-level effects of prescribed burning on
two Arizona wildfires. Canadian Journal of Forest Research, 35(7): 1714-1722.
95
Ritchie, M. W., Skinner, C. N., & Hamilton, T. A. (2007). Probability of tree survival after wildfire in an interior pine
forest of northern California: effects of thinning and prescribed fire. Forest Ecology and Management, 247(1), 200-
208.
96
Safford, H. D., Schmidt, D. A., & Carlson, C. H. (2009). Effects of fuel treatments on fire severity in an area of
wildland–urban interface, Angora Fire, Lake Tahoe Basin, California. Forest Ecology and Management, 258(5), 773-
787.
97
Schwilk, D. W., Keeley, J. E., Knapp, E. E., McIver, J., Bailey, J. D., Fettig, C. J., Fiedler, C. E., Harrod, R. J.,
Moghaddas, J. J., Outcalt, K. W. and Skinner, C. N. (2009). The national Fire and Fire Surrogate study: effects of
fuel reduction methods on forest vegetation structure and fuels. Ecological Applications, 19(2): 285-304.
98
Ager, A. A., Vaillant, N. M., & Finney, M. A. (2010). A comparison of landscape fuel treatment strategies to
mitigate wildland fire risk in the urban interface and preserve old forest structure. Forest Ecology and Management,
259(8), 1556-1570.
47 March 14, 2017
to restore forests and the natural role of fire,
105
and are embedded in management
strategies at local, state and national levels.
106
,
107
It is important to address emissions from California forest fires, and to address forest
health generally, from both a public health and climate change perspective. The Forest
Carbon Plan, as well as the 2017 Scoping Plan Update, will continue to explore the
interrelation of climate change and natural lands, as will research and policy
development work at ARB and throughout the State. This includes continued work
underway at ARB to refine radiative forcing estimates from emissions from wildfires; it
will be also be important to continue to assess how forest management strategies
affect fire behavior, emissions profiles, and climate change.
A. Progress to Date
California’s program to reduce emissions from transportation sources of black carbon
can serve as a blueprint for other jurisdictions seeking to address both the climate
change and public health impacts of mobile sources, particularly diesel engines. Over
the last few decades, ARB has employed a variety of strategies that has drastically
reduced black carbon emissions from mobile sources, including lower emission
standards, clean fuel requirements, in-use rules, incentives, and investments in
research and new technology. Diesel particulate filters have been instrumental in
reducing black carbon in on-road and major portions of the off-road sector. Today’s
diesel particulate filter-equipped trucks are more than 99 percent cleaner than those
manufactured in 1990. Measures have also been implemented on the State and local
level to reduce PM, and thus black carbon, emissions from non-mobile sources,
including residential burning, commercial cooking, and agricultural burning. Existing
measures are projected to cut mobile source emissions by 75 percent and total
anthropogenic emissions by nearly 60 percent between 2000 and 2020 (Figure 2).
99
Moghaddas, J. J., Collins, B. M., Menning, K., Moghaddas, E. E., & Stephens, S. L. (2010). Fuel treatment effects
on modeled landscape-level fire behavior in the northern Sierra Nevada. Canadian Journal of Forest Research,
40(9), 1751-1765.
100
Collins, B. M., Stephens, S. L., Roller, G. B., & Battles, J. J. (2011). Simulating fire and forest dynamics for a
landscape fuel treatment project in the Sierra Nevada. Forest Science, 57(2): 77-88.
101
Safford, H. D., Stevens, J. T., Merriam, K., Meyer, M. D., & Latimer, A. M. (2012). Fuel treatment effectiveness in
California yellow pine and mixed conifer forests. Forest Ecology and Management, 274, 17-28.
102
Stephens, S. L., McIver, J. D., Boerner, R. E., Fettig, C. J., Fontaine, J. B., Hartsough, B. R., Kennedy, P. L. and
Schwilk, D. W. (2012). The effects of forest fuel-reduction treatments in the United States. BioScience, 62(6): 549-
560.
103
Martinson, E. J., & Omi, P. N. (2013). Fuel treatments and fire severity: a meta-analysis. USDA For Service
Research Paper RMRS-RP103.
104
Stevens, J. T., Safford, H. D., & Latimer, A. M. (2014). Wildfire-contingent effects of fuel treatments can promote
ecological resilience in seasonally dry conifer forests. Canadian Journal of Forest Research, 44(8), 843-854.
105
Hessburg, P. F., Churchill, D. J., Larson, A. J., Haugo, R. D., Miller, C., Spies, T. A., North, M. P., Povak, N. A.,
Belote, R. T., Singleton, P. H. and Gaines, W. L. (2015). Restoring fire-prone Inland Pacific landscapes: seven core
principles. Landscape Ecology, 30(10): 1805-1835.
106
Wildland Fire Leadership Council. (2014). National Cohesive Wildland Fire Management Strategy. Available at:
https://www.forestsandrangelands.gov/strategy/ (Accessed 8/30/2016).
107
State of California. (2010). 2010 Strategic Fire Plan for California. Available at:
http://cdfdata.fire.ca.gov/fire_er/fpp_planning_cafireplan (Accessed 8/30/2016)
48 March 14, 2017
Figure 2: California’s Anthropogenic Black Carbon Emissions between 2000 and
2020 with Existing Measures
California has highlighted our accomplishments in discussions with other jurisdictions,
including a SLCP-focused side event, jointly hosted with Mexico, at the Conference of
Parties in Lima in 2014 and at international climate conferences in 2015. We will
continue to work closely with our partners in other states, in the federal government,
and internationally to highlight the successful actions California has taken, and will
continue to take, to reduce black carbon from mobile sources.
Mobile Sources
In 2000, ARB approved a Diesel Risk Reduction Plan, calling for an 85 percent
reduction in diesel PM emissions by 2020.
108
Diesel engines often operate for decades
after they are purchased, so while lower emission standards provide major emission
reductions, those reductions can take time to materialize as older engines are replaced
with new ones meeting the standard. To reduce risk and speed emission reductions,
ARB implemented in-use rules for on-road and off-road fleets to meet performance
standards through the use of alternative fuels, after-treatment retrofits, or replacement
of older vehicles with newer vehicles manufactured to current emission standards.
In-use on-road rules are expected to reduce black carbon emissions from on-road
sources by 80 percent between 2000 and 2020. ARB’s off-road rules apply to
approximately 150,000 off-road vehicles and are expected to reduce diesel PM
emissions by 20 percent between 2009 and 2023.
These regulations provide significant reduction in diesel PM exposure in communities
located near California’s major ports and intermodal rail yards and contribute to a
larger coordinated effort to reduce black carbon and PM emissions from all sources at
108
Final Diesel Risk Reduction Plan available at: http://www.arb.ca.gov/diesel/documents/rrpapp.htm
49 March 14, 2017
ports and rail yards.
109
Overall, since 2005, California has reduced diesel particulate
emissions, along with the associated health risks, by 70 percent at the largest ports
and 50–70 percent at the highest-risk rail yards.
Incentive programs, including the Carl Moyer Memorial Program, AB 923, AB 118 Air
Quality Improvement Program (AQIP), Alternative and Renewable Fuel and Vehicle
Technology Program (ARFVTP), and Proposition 1B, have provided the means to
transform California’s mobile fleet into one of the cleanest in the world. These
programs have provided more than $1.6 billion over the past 15 years to clean up
diesel engines and simultaneously reduce black carbon.
Cleaner fuels have been a cornerstone of ARB efforts to reduce mobile emissions,
enabling cleaner vehicle technologies that have reduced smog-forming emissions by
15 percent and reduced cancer risks from vehicle pollution by 40 percent. The Low
Carbon Fuel Standard provides a strong financial incentive to develop clean fuel
alternatives, which may also reduce black carbon. For example, renewable diesel and
biodiesel may reduce both PM and black carbon emissions compared to conventional
diesel, especially in engines where diesel particulate filter technology is not available.
California has also paved the way for increased penetration of zero-emission vehicles
(ZEV) through incentive programs and investment in new technology. The ZEV
regulation was first adopted in 1990, as part of the Low Emission Vehicle Program.
Today California is the world’s single largest market for light-duty passenger ZEVs,
accounting for 20 percent of all ZEVs on the road.
110
ARB will continue to lead in this
area with the Governor’s ZEV action plans to accelerate use of ZEVs and deploy
1.5 million passenger ZEVs in California by 2025. Providing financial and technological
pathways to accelerating growth in ZEVs and other advanced engine technologies
within California will push market development for clean and zero-emission vehicles
throughout the world, providing additional black carbon emission reductions outside of
California.
ARB is developing an integrated mobile source strategy to meet California’s air quality
and climate mandates, reduce petroleum use, and reduce near source risk.
Accomplishing this will require a transformation to near-zero and zero emission
technologies, cleaner renewable fuels, greater system and operational efficiencies, and
new approaches to passenger and freight mobility. These coordinated efforts will
provide California a clear path forward to reduce the State’s impacts on climate change
including reductions in black carbon emissions.
In April 2015, ARB released the Sustainable Freight Pathways to Zero and Near-Zero
Discussion Document that outlines initial steps ARB is taking to accelerate progress
109
Dallmann et al. 2011. Effects of Diesel Particle Filter Retrofits and Accelerated Fleet Turnover on
Drayage Truck Emissions at the Port of Oakland, Environmental Science & Technology, 45, 10773-
10779.
110
Draft 2015 ZEV Action Plan available at:
http://gov.ca.gov/docs/DRAFT_2015_ZEV_Action_Plan_042415.pdf
50 March 14, 2017
toward zero and near-zero emission freight vehicle and equipment technology in
California.
111
In July 2015, the Governor signed Executive Order B-32-15, which directs
the Secretaries of Transportation, Environmental Protection, and Natural Resources to
lead staff from the California Department of Transportation (Caltrans), ARB, CEC, and
the Governor’s Office of Business and Economic Development (GO-Biz), in the
development of the California Sustainable Freight Action Plan (Action Plan). The
Action Plan, released in July 2016, includes a long-term 2050 vision and guiding
principles for California’s future freight transport system along with targets for 2030:
Improve freight system efficiency 25 percent by 2030;
Deploy over 100,000 zero-emission vehicles/equipment and maximize near-zero
by 2030; and
Foster future economic growth within the freight and goods movement industry.
The Action Plan also identifies opportunities to leverage State freight transport system
investments, pinpoints actions to initiate over the next five years to meet goals, and
lists possible pilot projects to achieve concrete progress in the near term.
In May 2016, ARB released the Mobile Source Strategy, which includes a
comprehensive plan to control emissions from mobile sources in order to meet critical
air quality and climate goals over the next fifteen years.
112
In May 2016, ARB also
released the Proposed 2016 State Strategy for the State Implementation Plan (SIP),
113
which represents the elements of the Mobile Source Strategy necessary for the State
to meet federal air quality standards for ozone and fine particulate matter
(PM2.5). Based on continued work with local air districts and other stakeholders, ARB
released a revised version of the proposed State SIP Strategy in March 2017.
114
The
State SIP Strategy contains measures to reduce particulate matter and, thus, black
carbon emissions from mobile sources including implementation of low emission diesel
fuel, transitioning to zero-emission technologies and implementing additional emission
standards for some engine types. Particulate matter and black carbon emission
reductions will be realized from this and other proposed SIP measures, but have not
yet been quantified. The proposed SIP Strategy will be considered by the Board at the
March 2017 ARB Board meeting.
As emissions from mobile sources decrease, non-mobile sources will become an
increasingly important fraction of the black carbon inventory. The main non-mobile,
anthropogenic emission sources include residential wood combustion, fuel combustion
from stationary and small portable equipment, and industrial sources. Commercial
cooking and agricultural burning make up a smaller portion of emissions.
111
http://www.arb.ca.gov/gmp/sfti/sustainable-freight-pathways-to-zero-and-near-zero-emissions-
discussion-document.pdf
112
http://www.arb.ca.gov/planning/sip/2016sip/2016mobsrc_dd.pdf
113
https://www.arb.ca.gov/planning/sip/2016sip/2016sip.htm
114
https://www.arb.ca.gov/planning/sip/2016sip/rev2016statesip.pdf
51 March 14, 2017
Residential Wood Combustion
A number of local air districts have residential wood combustion rules, and are working
to make further progress in this category to meet air quality standards and protect
public health.
115
Strategies in place to reduce emissions from residential wood
combustion include winter burning curtailment, opacity emission limits, incentives to
replace old wood burning dev ices with more efficient models, and banning or limiting
wood burning devices in new and existing housing. Recently signed legislation
allocated $5 million of Cap-and-Trade revenue towards an incentives program to
reduce emissions from residential wood smoke. The U.S. EPA has recently introduced
a new source performance standard requiring manufacturers of residential wood
stoves, pellet stoves, forced air furnaces, and hydronic heaters to meet new lower
emission standards. Statewide black carbon emissions from residential wood
combustion have declined by nearly 20 percent between 2000 and 2013 in response to
existing district rules.
Stationary Fuel Combustion and Industrial Sources
Emissions from stationary fuel combustion will be addressed by a number of State and
federal planning efforts, including the SIP, Cap-and-Trade Program, increased building
energy efficiency and renewable energy goals, and the federal Clean Power Plan
(promulgated under Clean Air Act Section 111(d)). California’s Cap-and-Trade
regulation and the LCFS create market signals to incentivize efficiency improvements
as well as the use of biomass-derived liquid fuels that would emit lower levels of PM
and black carbon than traditional fossil fuels. The federal Clean Power Plan, which
accelerates the transition from coal towards lower carbon-intensive fuels for electricity
production, will reduce black carbon emissions, and emissions of other GHGs, across
the nation. Further emission reduction opportunities from stationary fuel combustion
and industrial processes may also be identified as part of the SIP process.
Commercial Cooking
Commercial cooking emissions are primarily
from charbroiling. The two types of
charbroilers include chain-driven, where food
moves mechanically through a semi-enclosed
broiler, and under-fired, where food is cooked
on a grill similar to a home barbeque. A
number of local air districts require air
pollution control technologies for chain-driven
broilers, reducing particulate emissions from
these charbroilers by over 80 percent.
Under-fired charbroilers are a larger source of PM, but no cost-effective air pollution
115
Yap and Garcia 2015. Effectiveness of residential wood-burning regulation on decreasing particulate
matter levels and hospitalizations in the San Joaquin Valley Air Basin, Am J Public Health, 105(4), 772-
778.
52 March 14, 2017
control technology has been identified to date. Air districts are working to develop air
pollution control devices for under-fired charbroilers. Demonstration projects for
emerging control technologies are in progress and it is anticipated that large districts
will develop rules for these emissions once cost-effective control technologies have
been identified.
Agriculture
Agricultural burning was historically used as a cost-effective way to remove agricultural
residue left behind on fields, help control weeds and pests, and prevent the spread of
plant disease, but emissions impacted local air quality and prompted concern for public
health. Various programs are currently administered by the local air districts in
coordination with ARB to reasonably regulate agricultural burning as required by state
law. The Sacramento Valley Rice Straw Burning Phasedown Program, local district
Smoke Management Programs, and San Joaquin Valley agricultural burning phase
down efforts have resulted in an approximately 70 percent reduction in black carbon
emissions from agricultural burning between 2000 and 2013.
Agricultural burning is controlled by the air districts whose programs must consider the
cost-effectiveness of alternatives (e.g., SB 705, H&SC 41855.5). Some agricultural
waste that was previously burned went to bioenergy facilities; however, many of these
facilities have shut down over the last few years due to their inability to procure long-
term power purchase contracts. The reduction in bioenergy capacity has already
resulted in some increase in agricultural burning due to a lack of cost-effective
alternatives.
116
ARB and sister agency staffs are targeting summer 2017 for a series of
summits to elevate the discussion on these and other waste-related issues. The
challenges with reducing agricultural waste burning, bioenergy production, and related
issues specific to the Central Valley will be explored as part of a Central Valley Ag-
Waste Burning Summit. Further, staff is planning with sister agencies to hold a Bio-
Economy Summit on the broader discussion of how to establish a California
bioeconomy based on a holistic approach to processing woody waste (forest and
agriculture), dairy manure, wastewater effluent, landfills, and other organic waste
streams, and capturing from these organic waste streams economically valuable
bioenergy, biofuels, engineered lumber, soil amendments including uniform fertilizer
products, and other beneficial products while maintaining or improving environmental
and public health protections.
In the short term, districts are forming working groups and evaluating additional funding
opportunities to help limit agricultural burning to the extent possible. However, there
are few proven cost-effective alternatives that can be deployed in the short term. One
option is to chip and grind the material for compost, incorporation into the soil, or to
provide to the public with mulch to replace lawns and reduce water consumption. In
the long term, advanced low emission technologies such as gasification or
116
http://www.valleyair.org/Board_meetings/GB/agenda_minutes/Agenda/2016/May/StudySession/final/i5.p
df
53 March 14, 2017
transportation fuels production should be explored to provide beneficial use for
agricultural residues. Programs to support clean energy and fuel production and
markets for wood products, would help provide opportunities for alternative beneficial
uses for this waste material.
Agriculture irrigation pumps are a small source of black carbon on a statewide level,
but may be an important local source. Multiple federal, state, and local governments
have provided incentives to convert agricultural diesel irrigation engines to either newer
cleaner diesel engines or to electric motors. This has led to black carbon emissions
from irrigation pumps declining by half between 2000 and 2013, with additional
reductions expected going forward in response to existing measures.
California has achieved tremendous reductions in black carbon emissions, especially in
the mobile sector, and even more reductions are expected as current measures are
fully implemented. In 2000, on-road mobile sources contributed a third of
anthropogenic black carbon emissions, but are projected to account for only a small
fraction of total emissions by 2030. Off-road mobile emissions, including aircraft,
watercraft, trains, small equipment, forklifts and farm equipment, have declined by over
a third since 2000, and are projected to decrease by another half by 2030.
However, meeting the 2030 anthropogenic black carbon emission target identified in
this SLCP Strategy requires additional emission reductions across multiple sectors.
Off-road mobile sources, along with stationary fuel combustion and residential wood
burning, will make up the majority of emissions by 2030 (Figure 3). Additional 2030
reductions will be realized through implementation of measures identified in plans
currently being developed, including the State Implementation Plans (SIPs). Additional
reductions are also expected through a district-lead commercial cooking regulation, but
the magnitude of emission reductions is currently unknown.
Figure 3: California’s 2030 Anthropogenic Black Carbon Emission Sources with
Existing Measures*
*Using 20-year GWP
54 March 14, 2017
B. Recommended Actions to Further Reduce Black Carbon Emissions
This section describes proposed new measures (summarized in Table 7 below) to
assist the State in meeting the proposed 2030 anthropogenic black carbon emission
target.
Table 7: Proposed New Black Carbon Emission Reduction Measures and
Estimated Emission Reductions (MMTCO
2
e)
1
Measure Name
2030 Annual
Emission
Reductions
2030 Annual
Emissions
2030 BAU
2
26
Residential Fireplace and
Woodstove Conversion
3
State Implementation Plan
Measures, and Clean Energy
Goals
3
4
2030 BAU with new measures
19
1
Using 20-year GWPs from the 5
th
Assessment report of the IPCC
2
Business As Usual (BAU) forecasted inventory includes reductions from implementation
of current regulations
3
Additional black carbon reductions will be realized from planned measures and are
expected to help the State meet the black carbon target. However, an estimate of
emission reductions is not currently available, but will be developed as part of these
planning efforts.
Residential Fireplace and Woodstove Conversion Measure
Residential wood combustion is forecast to be the largest individual anthropogenic
source of black carbon in 2030 if no new programs are implemented, accounting for a
quarter of anthropogenic black carbon emissions. Reducing 2030 residential wood
combustion black carbon emissions by half (3 MMTCO
2
e) would set California on a
path toward meeting the 2030 target in this SLCP Strategy.
Removal of old fireplaces and woodstoves and replacement with EPA-Certified
wood-burning devices, electric, propane, or natural gas heaters can provide long
lasting reductions in emissions of black carbon, criteria pollutants, and air toxics in
residential neighborhoods. Conversion to electric heating or natural gas heating
provides more certain emission reductions than conversion to certified wood-burning
devices. While certified wood-burning devices reduce fine particulate emissions,
certification values may not correlate well with in-home performance of wood
heaters,
117
and emission reductions are not as large as for non-wood technologies.
Electric heating or gas devices (including central HVAC) ensure local reductions of
particulate matter, black carbon and air toxics. To protect public health and use
117
U.S. EPA (2016). Process for developing improved cordwood test methods for wood heaters.
https://www.epa.gov/burnwise/process-developing-improved-cordwood-test-methods-wood-heaters
55 March 14, 2017
incentive dollars efficiently, non-wood burning devices should be prioritized where
possible. If wood burning devices are used, they should be the cleanest available
technologies, even if that technology is not yet required by federal law. Some areas
may require the use of wood burning equipment for safety, especially areas that
experience heavy snow which traps residents in homes, and where distributed natural
gas is not available or electricity loss is frequent. Additionally, natural gas, propane, or
electricity may cost more than wood in some regions, placing an additional financial
burden on homeowners.
Monetary incentives to stimulate removal of old wood burning devices are popular and
can achieve significant emission reductions. Incentive programs should prioritize
replacing the highest emitting devices used for primary sources of residential heating.
Removed wood burning devices should be destroyed and recycled to ensure
permanent emission reductions. Multiple air districts have invested in incentive
programs, but additional funding is necessary to continue to realize emission
reductions in this category. In addition, programs should be expanded to include all
regions of California. Incentive funding to support further district efforts could come
from a variety of national, State, and local resources. Assembly Bill 1613 includes
Cap-and-Trade expenditures of $5 million from the Fiscal Year 2016-2017 budget for a
residential woodstove replacement incentive program. In order to maximize emission
reductions, incentive programs should require that each device is professionally
installed by a certified installer. Improper installation can render a woodstove unsafe
and cause it to operate with much less efficiency which will increase emissions.
The ARB is proposing to work with the air districts to determine the most effective
approach to avoid new residential wood combustion emissions in California. This
could include encouraging the installation of non-wood burning centralized heating in
new construction. In areas where central heat is cost-prohibitive, the cleanest
available burning technology could be required.
Education and outreach are important tools to reduce emissions from residential wood
combustion. A broader public understanding of the health and environmental impacts
of wood smoke may cause voluntary changes in behavior to use other heating sources
and may cause individuals to avoid unnecessary burning both indoors and outdoors.
Education on proper burn practices may reduce emissions when wood is used, and is
essential to achieve full emission reductions from EPA-Certified wood burning devices.
Some districts have already implemented education programs, which should be
expanded to all parts of the State as part of this measure.
56 March 14, 2017
V. Reducing Methane Emissions
Methane is emitted from a wide range of fugitive sources and biological processes, and
is the second largest source of GHG emissions globally. Methane emissions are
growing globally as a result of human activities related to agriculture, waste handling
and treatment, and oil and gas production. Agriculture represents the largest methane
source in California, accounting for nearly 60 percent of methane emissions (Figure 4).
Landfills are the next largest source of methane, accounting for a fifth of statewide
methane emissions. Pipeline leaks, oil and gas extraction, wastewater, and other
industrial and miscellaneous sources make up the remainder of emissions. As
California relies on natural gas for a large fraction of its energy supply, it is critical to
increase supplies of renewable natural gas and minimize fugitive emissions of methane
from natural gas infrastructure.
In California, where natural gas may increasingly fuel trucks and heavy-duty vehicles,
we must ensure that the use of natural gas provides a climate benefit compared to the
diesel fuel it displaces. As we increase the number of facilities producing and using
renewable supplies of natural gas, hydrogen, or other fuels in a cleaner energy
economy, we must also take steps to minimize potential methane leaks from those
facilities. ARB and other agencies are funding research to identify high-methane “hot
spot” emitters in the oil and natural gas sector and other sectors throughout California.
Figure 4: California 2013 Methane Emission Sources*
* Using 20-yr GWP
California can cut methane emissions by 40 percent below current levels in 2030 by
avoiding or capturing methane from manure at large dairies, pursuing opportunities to
reduce methane emissions from enteric fermentation, significantly reducing disposal of
organics in landfills, and reducing fugitive methane emissions by 40 percent or more
from other sources.
A. Progress to Date
The State has taken important steps to reduce methane emissions from all its major
sources, but more needs to be done to control methane emissions, especially from
organic waste streams going to landfills and at dairies. In addition to reducing methane
57 March 14, 2017
emissions from these sources, capturing methane can provide fuel for power plants,
buildings, vehicles and industrial operations to displace fossil-based natural gas use.
Technologies to recover methane are already widely available and used in key sectors.
For example, some methane emissions from landfills, wastewater treatment facilities or
from manure at dairies are already captured and used as a renewable source of
natural gas to fuel vehicles or generate electricity. Some organic materials, such as
food waste and yard trimmings, are being redirected from landfill disposal to anaerobic
digestion and composting facilities to produce renewable energy, fuel and soil
amendments. Steps are also being
taken to reduce natural gas leaks from
oil and gas wells, pipelines, valves, and
pumps to improve safety, avoid energy
losses, and reduce methane emissions
associated with natural gas use.
In addition to ongoing efforts and
practices to reduce and use captured
methane for beneficial purposes,
several recent legislative and regulatory
actions will further support the reduction
or capture of methane within these
sectors. These actions prioritize
diverting organic material from landfills and include incentivizing the use of biogas for
transportation fuel, pipeline injection, or electricity generation. For example, aside from
the provisions in Senate Bill 1383:
California has established clear goals to reduce waste disposal, and divert
organic material from landfills for beneficial purposes. AB 341 (Chesbro,
Chapter 476, Statutes of 2011) established a State target to reduce the amount
of solid waste sent to landfills by 75 percent by 2020, through recycling,
composting, and source reduction practices. The 2014 Scoping Plan Update
calls for eliminating the disposal of organic materials at landfills, which would
potentially eliminate future methane emissions from landfills.
The Legislature recently took steps to further increase the diversion of organic
materials from landfills. AB 1826 (Chesbro, Chapter 727, Statutes of 2014)
requires businesses generating specified amounts of organic wastes to begin
arranging for the recycling and diversion of those wastes from landfill disposal
beginning in 2016. CalRecycle will provide an annual public update on the
disposal, diversion, and recycling of organics, beginning in 2016, pursuant to
this mandate. AB 1594 (Williams, Chapter 719, Statutes of 2014) re-classifies
the use of green waste for landfill “alternative daily cover” as disposal, beginning
in 2020. AB 876 (McCarty, Chapter 593, Statutes of 2015 ) requires local
governments, beginning August 2017, to assess the amount of organic waste
that will be generated in a region during a 15-year period and identify locations
58 March 14, 2017
for new or expanded organic waste recycling facilities capable of handling this
material. AB 1045 (Irwin, Chapter 596, Statutes of 2015) directs CalEPA and
CalRecycle to coordinate with ARB, the State Water Resources Control Board,
and CDFA to develop and implement policies to aid in diverting organic waste
from landfills by promoting the composting of organic waste and by promoting
the appropriate use of that compost throughout the State. SB 1383 requires
CalRecycle to develop regulations that will reduce disposal of organic waste by
50 percent of 2014 levels in 2020 and by 75 percent of 2014 levels in 2025.
Methane emissions from landfills are controlled under ARB's Landfill Methane
Control Measure, which was approved in 2009. The regulation complements
previously existing federal and local air district landfill rules by requiring
owners and operators of certain previously uncontrolled municipal solid waste
landfills to install gas collection and control systems, and requires existing and
newly installed gas and control systems to operate in an optimal manner. The
regulation allows local air districts to voluntarily enter into agreements with
ARB to implement and enforce the regulation and to assess fees to cover
costs.
Senate Bill 1122 (Rubio, Chapter 612, Statutes 2012), directs the California
Public Utility Commission (CPUC) to require the State’s investor owned utilities
to develop and offer 10 to 20 year market-price contracts to procure an
additional 250 megawatts of cumulative electricity generation from biogas
facilities that commence operating on or after June of 2013. Eligible projects
and sources include biogas-generated electricity from wastewater treatment,
municipal organic waste, food processing, dairy manure and agricultural organic
material, and sustainable forest materials.
The Low Carbon Fuel Standard (LCFS) requires transportation fuel providers to
procure clean fuels to reduce the carbon intensity of California’s fuel mix. In
doing so, it provides a market signal to incentivize developing clean fuel options,
including capturing or avoiding methane emissions and using associated
renewable natural gas as a transportation fuel. Some LCFS pathways related
to renewable natural gas have the lowest carbon intensities of pathways to date.
Specifically, the production of biomethane from high solids anaerobic digestion
of organic (food and green) wastes has a carbon intensity of -15 gCO
2
/MJ, and
a recently approved pathway for biogas from a dairy digester project has a
carbon intensity of -276 gCO
2
/MJ. If LCFS credit prices are $100/MT, as they
have been recently, the value of LCFS credits from these pathways is about
$1.50 per diesel-gallon equivalent and $5.00 per diesel-gallon equivalent,
respectively (or about $11/MMBtu and $36/MMBtu of natural gas, respectively).
Transportation fuel derived from biogas may also qualify for Renewable
Identification Number (RIN) credits as part of the U.S. EPA Renewable Fuel
Standard 2, which could add additional value to these types of projects.
59 March 14, 2017
Assembly Bill 1900 (Gatto, Chapter 602, Statutes of 2012) directed the CPUC to
adopt natural gas constituent standards (in consultation with ARB and the Office
of Environmental Health and Hazard Assessment). The legislation is also
designed to streamline and standardize customer pipeline access rules, and
encourage the development of statewide policies and programs to promote all
sources of biomethane production and distribution. It also directs the CEC to
identify constraints to the use and interconnection of biomethane and offer
solutions in its Integrated Energy Policy Report. The CPUC has adopted natural
gas constituent standards and created a program to offset a portion of gas
producers' costs of connecting to utility pipelines. This program is currently
funded at $40 million, and may offset half of interconnection costs, up to
$3 million per project or $5 million for a dairy cluster project, per Assembly Bill
2313 (Williams, Chapter 571, Statutes of 2016). Assembly Bill 2313 also
requires the CPUC to extend this program through December 31, 2016.
Pursuant to Assembly Bill 1257 (Bocanegra, Chapter 749, Statutes of 2013), the
CEC has released a report identifying strategies for maximizing the benefits
obtained from natural gas as an energy source.
118
The report examines
strategies and recommendations regarding natural gas, including low emission
resources such as biogas and biomethane; the use of natural gas as a
transportation fuel; centralized and distributed electricity generation; cooking,
cooling, and space heating; engine and appliance applications; its role in the
development of zero net energy buildings; and GHG emissions associated with
the natural gas system. The report also examines infrastructure and storage
needs and pipeline and system reliability concerns.
ARB's Cap-and-Trade Program will reduce demand of fossil fuels and provide
incentives to accelerate efficiency and clean energy. Compliance Offset
Protocols under the Cap-and-Trade Program provide methods to quantify,
report, verify, and credit GHG emission reductions from sectors not covered by
the Cap-and-Trade Program. The Offset Protocols include a livestock protocol,
rice cultivation protocol, and mine methane capture protocol.
119
The livestock
protocol credits operators who voluntarily install manure biogas capture and
destruction technologies. The rice protocol allows compliance offset credits to
118
AB 1257 Natural Gas Act Report: Strategies to Maximize the Benefits Obtained from Natural Gas as
an Energy Source, California Energy Commission, November 2015.
http://docketpublic.energy.ca.gov/PublicDocuments/15-IEPR-
04/TN206470_20151030T160233_STAFF.pdf
119
As is discussed in more length in the CEQA document accompanying this document, the livestock
offset protocol would likely cease accepting new projects for offset credits after the effective date of
substantive regulations controlling agricultural methane from dairies; however, existing projects could
continue generating credits throughout their crediting periods. ARB expects this continued funding
stream, along with increased focus on regulatory and incentive measures in this area, to mean many
projects now receiving offsets to continue functioning at the end of the crediting period; this, along with
new regulations, will produce significant net reductions in methane even if some offset projects cease to
function. This transition from offset protocols towards regulations has long been ARB policy.
60 March 14, 2017
be issued for emission reductions achieved by switching to rice cultivation
practices that reduce methane emissions. The mine methane capture protocol
incentivizes capturing methane that would otherwise be vented into the
atmosphere from active and abandoned mines.
A broad array of these and other state programs reducing dependence on fossil fuels
are also already working to reduce methane emissions, especially from the oil and gas
sector. Ultimately, fugitive methane emissions in the oil and gas sector are a function
of our demand for these products. As state policies continue pushing reductions in
overall energy use and our evolution away from conventional oil and natural gas, they
will also help to reduce emissions of methane from the production and distribution of
fossil fuels. In particular, efforts to improve efficiency or electrify appliances, buildings,
and vehicles will not only reduce energy use and CO
2
emissions, but also serve to
reduce or avoid fugitive methane emissions from the production, and potentially
transmission and distribution, of oil and natural gas.
The State has strong targets to reduce the use of natural gas and petroleum by 2030,
and several studies show that California must virtually eliminate the use of all fossil
fuels to meet its 2050 climate targets. Notably, Governor Brown has called for
reducing on-road petroleum use by up to 50 percent by 2030, and Senate Bill 350 (De
León, Chapter 547, Statutes of 2015) requires the State to procure 50 percent of its
electricity from renewable resources by 2030 and double the rate of natural gas and
electricity efficiency savings. ARB’s 2016 Mobile Source Strategy describes actions to
achieve the State’s air quality and climate targets from the transportation sector, and
cut petroleum use by 50 percent by 2030. The State’s Low Carbon Fuel Standard is
sending a clear signal to the market that is leading to investment and use of a broad
spectrum of cleaner transportation fuels in California including electricity, biogas, as
well as biodiesel and renewable diesel, all of which are displacing petroleum. Further,
the State’s Cap-and-Trade Program encourages efficiency and use of non-fossil
energy sources across all sectors of the economy, and various programs provide
billions of dollars in incentives to support energy efficiency throughout the State.
Effectively implementing these actions and programs will significantly cut demand for
fossil fuels and associated CO
2
emissions on trajectories we need, while further
reducing methane emissions from oil and gas systems. As State agencies implement
and refine these programs and plans, they will seek opportunities to better align them
with these objectives. Additionally, State agencies will support research to inform
appropriate approaches to continue its transition away from fossil fuels.
Further, several efforts are underway at the CEC and ARB to improve emissions
monitoring to help identify sources of fugitive methane emissions and reduce them.
For example, the CEC provided research funding for operation of a mobile leak
detection platform. In 2017, ARB will release a Request for Proposal (RFP) to collect
emissions data from oil production wastewater ponds. Results from this contract are
expected in 2018-2019, and if they indicate that these ponds are significant sources of
methane, ARB may initiate a regulatory process to reduce those methane emissions.
61 March 14, 2017
Additionally, ARB and NASA's Jet Propulsion Laboratory are collaborating to identify
large "hot spot" methane sources through a systematic survey of high methane
emitters throughout California. This project will use aerial and ground measurement to
survey oil and gas fields and infrastructures, dairies, feedlots, digesters, landfills, rice
fields, and wastewater treatment facilities to provide a greater understanding of
methane sources. Additionally, Assembly Bill 1496 (Thurmond, Statues of 2015,
Chapter 604) requires ARB to undertake monitoring and measurements of high-
emission methane “hot spots” and conduct lifecycle GHG emission analysis for natural
gas produced in and imported into California. Finally, ARB is actively participating in
the Megacities Carbon Project being conducted in the South Coast Air Basin, which is
developing and testing methods for monitoring various GHG emissions to link
monitored concentrations to emission activity. These efforts will help identify significant
fugitive methane sources in California and improve leak detection.
Collectively, these measures will help to keep methane emissions in California fairly
steady through 2030. However, the science-based pathway to limiting global warming
below 2
o
C—including meeting the State's goal to reduce GHG emissions by 40 percent
below 1990 levels by 2030—requires further reducing methane emissions in California.
Significant opportunity remains to further reduce methane emissions from the major
sources in the State (Figure 5). Doing so will require overcoming various economic
and institutional barriers, but will provide a wide range of economic and environmental
benefits throughout the State, especially where they are most needed.
Figure 5: California’s 2030 Methane Emission Sources with Existing Measures*
*Using 20-year GWP
B. Recommended Actions to Further Reduce Methane Emissions
California can reduce methane emissions by 40 percent below current levels through a
collaborative and mixed approach that combines incentives, public and private
investment and partnerships, systematic planning, and regulatory efforts. California’s
strategy to reduce methane emissions reflects and supports the variety of approaches
and options available to achieve the goal in the most efficient, cost-effective, and
environmentally-sensitive manner. This SLCP Strategy promotes and encourages
opportunities for industry innovation, the efficient use of existing infrastructure and
62 March 14, 2017
facilities, and supports the development of integrated systems across various sectors
to handle, process, and reuse waste materials and captured methane. For example,
significant anaerobic digestion and additional composting infrastructure capacity needs
to be established and expanded, and appropriate market opportunities need to be
developed for compost and captured methane before the State can fully use existing
organic waste streams for beneficial purposes. State agencies will work with industry
and other stakeholders to support and accelerate new project development and
activities to maximize methane emission reduction at existing facilities. The State will
also work with communities and regional stakeholders to plan and develop integrated
infrastructure systems and markets to reduce wastes and associated emissions in the
most environmentally-sensitive manner. By investing early and committing to the
immediate resolution of issues that hinder progress, California can make significant
progress in the near-term, and capture associated benefits.
There are a host of activities underway at the State and Federal level, and by gas
utilities, to reduce methane emissions from the natural gas system. In particular,
regulations are being developed to reduce fugitive methane emissions from the oil and
gas production, processing and storage sector, and from the natural gas transmission
and distribution system. By effectively implementing these policies, and supporting
them with continued and improved emissions monitoring, California can match the
federal government’s goals to reduce methane emissions from the oil and gas sector
by 40-45 percent by 2025. The State will aim to extend successful approaches to
reduce emissions from the oil and gas sector to other sectors, and overall, to reduce
fugitive methane emissions from all sources by similar levels by 2030.
Table 8, below, identifies emission reductions by sector to reduce economy-wide
methane emissions by 40 percent below current levels by 2030. The expected 2030
annual emission reductions for each sector are based on: 40 percent reduction in dairy
and livestock sectors' emissions from 2013 levels by 2030; 50 percent diversion of
organic waste by 2020 and 75 percent diversion of organic waste by 2025 from 2014
levels; 40 percent reduction of wastewater and other industrial sources methane by
2030; and 45 percent reduction of oil and gas methane by 2030. The emission
estimates in the table are based on currently available information and
projections. They may change as new information becomes available or as measures
are more fully developed.
63 March 14, 2017
Table 8: Proposed New Methane Emission Reduction Measures and 2030
Estimated Emission Reductions (MMTCO
2
e)
1
Measure
2030 Annual
Emission
Reductions
2030 Annual
Emissions
2030 BAU
2
117
Dairy and Other Livestock
(Manure and Enteric
Fermentation)
26
Landfill
4
Wastewater, Industrial and
Other Miscellaneous
Sources
7
Oil and Gas Sector
8
2030 BAU with new measures
71
3
1
Using 20-year GWPs from the 4
th
Assessment report of the IPCC
2
"Business As Usual" (BAU) forecasted inventory includes reductions from
implementation of current regulations
3
The specific annual reduction values shown above do not sum exactly to the total
shown due to rounding error.
1. Dairy Manure
California’s dairy and livestock industries account for more than half of the State's total
methane emissions and for about five percent of the State’s GHG inventory, based on
100-year GWPs (using 20-year GWPs, the industries account for about 12 percent of
California’s GHG emissions). Twenty-five percent of the State’s methane emissions
comes from manure management practices at dairies, primarily from lagoon storage of
flushed manure from the State's milking cows. Nearly 20 percent of the State’s
methane emissions come from enteric fermentation (mostly belching) of dairy cows,
and another ten percent comes from enteric fermentation of non-dairy livestock
(primarily other cattle).
California has the most dairy cows in the country and the highest aggregated (from
manure management and enteric fermentation) dairy methane emissions. The State
also has higher per-milking cow methane emissions than most of the rest of the United
States, due to the widespread use of flush water lagoon systems for collecting and
storing manure. Milk production feed efficiency at California dairies, however, is
among the best in the world, making enteric fermentation emissions per gallon of milk
from California dairy cows relatively low.
Senate Bill 1383 directs ARB to develop a manure management strategy that will
reduce dairy and livestock sector methane emissions by up to 40 percent from 2013
levels by 2030. In doing so, SB 1383 recognizes the importance of addressing
California's largest source of methane and the opportunity presented by modifications
64 March 14, 2017
to manure management practices (See Appendix B). Manure management at dairies
offers one of the greatest opportunities to reduce methane emissions from these
sectors (methane from manure management at California's non-dairy livestock
operations comprise less than five percent of overall manure methane). Accordingly,
California will aim to structure incentives, policies, regulations, and research to support
significant methane emission reductions from dairy manure management. The extent
to which regulations will be needed in achieving these reductions will be evaluated and
may be adjusted as necessary, commensurate with the SB 1383 provisions.
Through this SLCP Strategy and related efforts, we have a tremendous opportunity to
work with the industry to reduce methane emissions from the State’s largest source,
while creating economic value in farming communities. If markets are fully enabled,
efforts to reduce methane from manure management at California dairies could lead to
billions of dollars of investment and thousands of new jobs, concentrated in the Central
Valley. Depending on the strategies pursued to reduce emissions, individual dairies
may be able to reduce emissions while generating new revenue streams, and the
industry as a whole may be able to meet the targets established in this SLCP Strategy
at little or no net cost (see Chapter VIII).
However, revenues in some cases are highly dependent on environmental credit and
energy markets, as well as on improving access to the common carrier natural gas
pipeline system. Recent legislation, including SB 1383 and AB 2313, establish
frameworks and priorities to help address these potential barriers. SB 1383 requires
ARB, CPUC, and CEC to institute measures to increase the economic certainty
associated with environmental credit generation and to encourage development of
dairy RNG projects and associated infrastructure. Additionally, AB 2313 increases
utility incentives to help offset costs of pipeline interconnection, especially for projects
from dairy clusters. And AB 1613 commits $50 million in Cap-and-Trade funds to
support methane reductions at dairies during the 2016/2017 fiscal year.
Ultimately, a mix of tools will be used to reduce methane emissions from dairy and
livestock manure management. The process for developing strategies will be built
around extensive stakeholder involvement, consistent with SB 1383, AB 32 and other
relevant laws. Among other factors, the process to develop recommended strategies
will require close coordination with the dairy industry and will consider public input;
available financial incentives; technical, market, and regulatory barriers to the
development of dairy methane emission reduction projects; research on dairy methane
emission reduction projects; and the potential for emissions leakage, as well as steps
to minimize any leakage that might otherwise occur.
Among the emission reduction measures ARB, CDFA, and stakeholders will consider
in developing these strategies are the following:
65 March 14, 2017
Switching from Flush Water Lagoon Systems
Dairy methane emissions may be significantly reduced by switching from flush water
open lagoon systems to anaerobic digesters or other systems such as solid manure
management practices. Using solid (e.g. slurry vacuum or scrape) manure systems
with a digester (e.g. plug-flow, above ground tank) can enable easier transport and
storage of manure off-site or to centralized digester systems. The benefits can include
improved economies of scale, biogas production efficiencies, nutrient management,
water efficiency, and water quality compared to flush systems paired with flood
irrigation systems. Dairy manure can also be mixed with other organic materials—such
as those diverted from landfills or processed at wastewater treatment plants—to
improve digester performance and economics. Centralized digesters designed and
sited so as to efficiently process these waste streams can play a key role in helping
California meet its organic diversion and climate goals.
Dairies with flush water lagoon systems typically flood irrigate dairy feed crops, such as
corn silage and alfalfa, to dilute and disperse nutrients from manure in the lagoon. This
practice can lead to soil and groundwater contamination despite being subject to
regulation by regional water quality control boards, including the Dairy General Order in
the Central Valley. Some agricultural practices have historically led to legacy
pollutants contaminating groundwater, which could continue if unabated. To address
this, regional water boards issue waste discharge requirements that include
development and implementation of nutrient management plans, water quality
monitoring, and corrective actions when impairments are found. Switching to systems
such as solid manure management may lead to air or water quality challenges,
however, which need to be fully considered. Ultimately, the optimal mix of
technologies and manure management practices to reduce methane emissions, protect
air and water quality, and support dairy economics will depend on dairy- and location-
specific factors.
Pasture-Based Dairy Management
In some instances, pasture-based systems may be a viable option, but tradeoffs can
limit their feasibility. In a pasture system, manure decomposes aerobically, avoiding all
but trace amounts of methane emissions, though potential nitrogen impacts may arise.
Many organic milk producers rely on pasture systems, and pasture systems are
commonly used in other states and at smaller dairies in the coastal and northern parts
of California. For larger dairies and those in the Central Valley, pasturage would
require using significantly more irrigated land, may require supplemental feed, and (in
the case of Central Valley dairies) may require construction of shade structures and
other infrastructure to alleviate heat exposure-related impacts on animal welfare.
Pasture dairies may face potential nutrient management and water quality issues, and
are required to maintain the capacity to store liquids from milking parlor operations
(chilling milk, cleaning facilities, etc.) for a 100-year stormwater event. Additionally,
milk production and feed efficiencies are lower in pasture systems, requiring more
66 March 14, 2017
cows to produce the same amount of milk. Pasture systems also limit the ability to
manage manure as a valuable organic waste resource.
While there are potential limitations to using pasture dairy models, there may also be
potential benefits associated with these systems that need further evaluation. Among
these potential benefits are improved animal welfare, lower on-farm air emissions,
improved aesthetics, and reduced impacts to water quality. Further evaluation of
pasture systems can fully characterize their potential benefits, costs and limitations
relative to conventional dairy models. Additionally, hybrid models that employ aspects
of both pasture and conventional systems should also be investigated for their potential
benefits and impacts for dairy and livestock operations.
Installing Anaerobic Digestion Systems
Dairy operators may determine that capturing and utilizing manure methane by
installing an anaerobic digestion system is more advantageous than avoiding methane
emissions through conversion to practices such as a pasture-based dairy model,
providing the current barriers can be sufficiently addressed. Captured biogas from
dairy manure can be used to power farm trucks and equipment, upgraded for injection
into natural gas pipelines, used as a transportation fuel, or used to generate on-site
renewable electricity and heat. However, tapping into this resource in California has
been complicated in part due to air quality constraints, especially in the Central Valley
and Southern California. Utilizing newer, cleaner technologies can help to overcome
the air quality permitting issues that have previously hindered project development. In
particular, technologies or strategies that reduce or eliminate criteria pollutant and toxic
emissions should be encouraged in both incentive and regulatory programs,
particularly in areas with severe or extreme air pollution. Using ARB-certified
distributed generation technologies, such as microturbines or fuel cells, can
significantly cut NO
x
emissions compared to internal combustion-based power
generation. Injecting upgraded biomethane into the natural gas pipeline can avoid
most new combustion or associated emissions. As part of an integrated strategy that
includes replacing diesel trucks and equipment with certified ultra-low NO
x
equipment,
fueling vehicles with dairy-derived biomethane could help to reduce criteria pollution in
impacted air basins.
Given existing incentives and complementary climate and energy programs, manure-
management conversions that produce electricity and vehicle fuel are potentially
profitable; however, most require significant up-front capital investment. Among the
most promising are those that produce biomethane for injection into a common-carrier
pipeline. This approach involves construction of connecting pipeline segments, and
installation of biogas upgrading equipment capable of meeting the pipeline-quality
biomethane standards developed in response to AB 1900 (Gatto, Chapter 602,
Statutes of 2012). While these barriers have not been overcome completely, AB 2313
and SB 1383 clearly demonstrate the State’s commitment to developing policies to
encourage infrastructure development and procurement of biomethane from dairy
biogas projects.
67 March 14, 2017
In consideration of potential emission reduction measures, including those described
above, the State will encourage and support research and near-term actions by dairies
to reduce emissions through market support and financial incentives. In line with these
policies, $50 million in Cap-and-Trade funds have been appropriated by the Legislature
as part of the Fiscal Year 2016-2017 budget for reducing methane from manure
management through the development of anaerobic digestion systems and the
exploration of non-digestion related options for reducing manure methane. These
funds will be administered by CDFA through the Dairy Digester Research and
Development Program
120
and the newly created Alternative Manure Management
Program.
121
Initially, as the $50 million in Cap-and-Trade funds become available, the State will
incorporate lessons learned from previous incentive programs to improve the
effectiveness and efficiency of new incentives, while overcoming persistent barriers
and challenges. At the same time, ARB will initiate a rulemaking process, pursuant to
SB 1383, to develop regulations for reducing dairy and livestock manure emissions in
California. The process will include considering research on manure management
practices and developing reporting and recordkeeping regulations to improve
California-specific data and ARB’s GHG emission inventory. This information will
shape the emission control regulations pursuant to this SLCP Strategy, along with
information obtained through other collaborative efforts. This coordinated approach will
aim to develop a competitive, low-carbon dairy industry in California and avoid
emissions leakage.
Specifically, California will take the following steps to significantly cut methane
emissions from manure management at dairies:
Accelerate Early Project Development through Incentives and Market
Development
As provided under SB 1383, the State will support efforts to accelerate project
development and help the industry reduce emissions before regulatory requirements
take effect. In particular, the State will work to support improved manure management
practices through financial incentives, collaboration to overcome barriers, and other
market support.
Continued State funding or incentives should support initial infrastructure investments
to secure methane emission reductions, support future low-carbon biomethane
utilization goals, increase resource use efficiency (e.g. conserve water), improve
nitrogen application precision, and support market opportunities for the use of
biomethane and soil amendment products. CDFA estimates that at least $100 million
will be needed for each of the next five years to support the development of necessary
120
Information on the CDFA Dairy Digester Research and Development Program is available at:
https://www.cdfa.ca.gov/oefi/ddrdp/
121
Information on the CDFA Alternative Manure Management Program is available at:
https://www.cdfa.ca.gov/oefi/AMMP/
68 March 14, 2017
manure management infrastructure in the form of grants, loans, or other
incentives. The economic analysis in Chapter VIII suggests that this level of funding
could significantly accelerate project development by offsetting capital costs and
economic risks. The SB 1383 requirement that ARB develop a pilot financial
mechanism to reduce the economic uncertainty associated with the value of
environmental credits from dairy-related transportation fuel projects should further
accelerate project development. Different types of funding mechanisms and levels of
support may be appropriate for different types of projects.
ARB, CDFA, State Water Resources Control Board, and Regional Water Quality
Control Boards' staff will establish a working group with other relevant agencies and
stakeholders to focus specifically on developing measures to overcome the barriers
that have constrained dairy manure projects in the past. The group will aim to monitor,
ensure, and accelerate market and institutional progress and report its findings to the
Legislature. It may cover several topics, including: project finance, permit coordination,
CEQA, feed-in tariffs, simplified interconnection procedures and contracts, credits
under the LCFS, increasing the market value of manure products, and uniform biogas
pipeline standards. This group will be coordinated with similar working group efforts
related to anaerobic digestion, composting, energy, healthy soils, and water.
Additionally, State agencies will coordinate activities with federal agencies, including
the U.S. Department of Agriculture and U.S. Department of Energy, to align common
efforts and attract federal investment to California. Further, ARB will work with State
and regional water quality agencies to capitalize on opportunities for joint development
of measures that conserve water and improve water quality. Similarly, ARB will work
with the air districts to ensure opportunities for air quality efforts are developed jointly.
In many cases, converting to solid manure management systems or installing
anaerobic digesters at dairies may not yet be cost-effective if the only marketable
products are renewable electricity and/or renewable natural gas. If these revenue
streams can be augmented with revenues from compost or other soil amendment
products, and from environmental credits, these conversions may offer attractive rates
of return for farmers and investors.
122
However, markets for these other products need
further support before they can offer returns that are reliable enough to help secure
project financing. CalRecycle, CDFA, and other agencies are working together to
support healthy soils through composting and building markets for soil amendment
products in the State. Enabling pipeline injection of biomethane and minimizing
associated costs will help direct dairy biogas into the transportation sector and allow for
the generation of LCFS and RIN credits, which could provide an especially valuable
revenue stream.
123
The State will continue to support these efforts.
122
For example, one report estimates that the average internal rate of return for dairy digester projects in
the U.S. that only capture value from energy production would be about 8 percent in a mid-valuation
scenario, but would increase to 38 percent if value can be captured from soil amendments and markets
for environmental credits. Informa Economics (2013) National Market Value of Anaerobic Digester
Products, Prepared for the Innovation Center for U.S. Dairy, February.
123
Under the LCFS, ARB recently approved a dairy digester fuel pathway with a carbon intensity
of -276 gCO
2
e/MJ. http://www.arb.ca.gov/fuels/lcfs/2a2b/apps/calbio-sum-122115.pdf At credit prices of
$100/MT, these credits could be worth about $5 per diesel gallon equivalent.
69 March 14, 2017
Research the Reduction Potential of Manure Management Practices
While the need and potential to reduce methane emissions from dairy manure is clear,
some potentially effective strategies are still in the development stage. ARB will work
with other state agencies through the Climate Action Team Research Working Group,
the dairy industry, and other stakeholders to establish mechanisms to identify and fill
information gaps, as required by SB 1383. In particular, SB 1383 directs the agencies
to consider research about the emissions-reduction potential of solids separation,
enteric fermentation, and conversion of flush systems to solid manure management
systems. However, little data exists to quantify costs and benefits associated with
these practices. Additionally, some uncertainty remains regarding cross-media
impacts and appropriate emissions-accounting methods. ARB and CDFA will continue
to support research to eliminate information gaps and improve understanding of
potential manure management practices and their associated methane reduction
benefits, as well as potential air quality or water quality impacts.
Develop Regulations to Ensure Emission Reductions
In coordination with CDFA and local air quality and water quality agencies, ARB will
initiate a rulemaking process to reduce manure methane emissions from the dairy
sector consistent with the objectives in this SLCP Strategy. As noted earlier, the
rulemaking process will involve extensive stakeholder engagement and consideration
of multiple factors. The regulations are to be implemented on or after January 1, 2024.
Pursuant to SB 1383, ARB, in consultation with CDFA, will analyze the progress dairies
are making in achieving the goals in the Strategy by July 1, 2020, and may make
adjustments to those goals if sufficient progress has not been made.
The rulemaking process will first focus on developing measures to require regulated
parties to both report and maintain records covering the parameters that affect GHG
emissions at California dairies and other livestock operations. Reported information
will be used to refine inventory quantification, evaluate policy effectiveness, assess
methane reduction progress, and aid in future policy planning and regulatory
development. ARB will work with other State agencies and industry groups to improve
outreach on new reporting requirements, as well as merge reporting activities with
current forms and requirements to avoid duplicative reporting wherever feasible.
Emission control regulations will be designed to support and complement existing
programs. In particular, regulatory requirements to achieve large emission reductions
from the sector will affect incentives for methane reduction projects, such as the
availability and amount of credits under the Cap-and-Trade Program and LCFS. Once
the regulatory requirements are in effect, credits for avoided methane emissions under
the LCFS or the Cap-and-Trade Programs would not be available for new projects as
the reductions would not be additional to regulation (which becomes the business-as-
usual case). However, projects in place before the new requirements take effect would
still be able to generate credits for avoided methane emissions for their current
70 March 14, 2017
crediting period, which is ten years of operation. After a regulation takes effect, credits
for new projects under the LCFS would still be available, but would be based only on
the displacement of petroleum fuel. ARB will clarify the impact of potential regulations
and provide guidance by January 1, 2018, as required by SB 1383.
2. Dairy and Livestock Enteric Fermentation
Methane is also produced by the microorganisms involved in the digestive processes in
the stomachs of dairy cows and other ruminants, such as sheep, goats, buffalo and
cattle. This process is referred to as enteric fermentation. These emissions account
for approximately 30 percent of California’s methane inventory, making it important to
explore strategies to reduce emissions from these sources to meet the State’s
40 percent economy-wide methane emission reduction target.
Strategies that have been investigated to reduce enteric fermentation include
increasing production efficiencies to reduce the amount of methane produced for a
given amount of product, breeding animals for lower methane production, gut microbial
interventions, and changes to nutrition and animal management. Various studies are
pointing to new feed supplements or dietary changes that show potential for reducing
enteric fermentation emissions significantly without affecting milk production.
124
,
125
However, further research is needed to validate initial findings, fully evaluate the
viability of these strategies to California, assess their associated costs and co-benefits,
potential impacts on animal productivity, effects on animal and human health, other
environmental impacts, and GHG and air toxic emissions associated with feed
lifecycles.
The Legislature recognized the important role of enteric fermentation emission
reductions in meeting the goals in SB 1383 by requiring consideration of enteric
fermentation research, allowing voluntary reductions to be considered in the design of
dairy and livestock emission reduction measures, and by providing that these
reductions count towards economy-wide methane emission reductions targets. It also
recognized the limited available information and potential impacts associated with
achieving enteric fermentation emission reductions, allowing only incentive-based
approaches to these reductions until ARB, in consultation with CDFA, determines that
cost-effective and scientifically validated methods for reducing enteric emissions are
available. In addition, adoption of an enteric emission reduction method must not
compromise animal health, public health, or consumer acceptance of dairy products.
124
Hristov et al (2015) An inhibitor persistently decreased enteric methane emission from dairy cows
with no negative effect on milk production, Proceedings of the National Academy of Sciences,
112(34):10663-10668. www.pnas.org/cgi/doi/10.1073/pnas.1515515112
125
Moate et al (2014) Grape marc reduces methane emissions when fed to dairy cows, Journal of Dairy
Science, 97(8):5073-5087. http://dx.doi.org/10.3168/jds.2013-7588
71 March 14, 2017
Research Mitigation Strategies for Enteric Fermentation
Federal and State agencies, industry, and academia will collaborate on research and
demonstration projects through available funding mechanisms (e.g. ARB's annual
research solicitation program). As with research on manure management practices,
the Climate Action Team Research Working Group can coordinate with other state
agencies, the dairy industry, and other stakeholders to develop research on methane
reductions from enteric fermentation. In addition, progress will continue to be
monitored to develop strategies that can help to reduce enteric fermentation emissions
from dairy cows and livestock in the California context. Once mitigation strategies
have been successfully evaluated, long-term emission reduction potential and goals
can be established on a broader scale.
The schedule for implementing the dairy- and livestock-related directives in SB 1383 is
summarized in Table 9.
Table 9: Timeline for Dairy and Livestock Methane Reduction Measures
Action
Deadline
ARB approves SLCP Strategy and begins Implementation
Expected approval date………………………………………
Statutory deadline…………………………………………….
First Quarter 2017
By January 1, 2018
ARB, CDFA, State Water Resources Control Board and
Regional Water Quality Control Boards in coordination with
the energy agencies, will work with the dairy industry to
establish a dairy workgroup to identify and address barriers
to development of dairy methane emission reduction
projects
First Quarter 2017 and ongoing
CDFA announces awardees for GGRF grant program for
achieving early and extra methane emission reductions from
dairy and livestock manure
June 2017
(funds encumbered June 2018)
CPUC, in consultation with ARB and CDFA, directs utilities
to develop at least 5 dairy biomethane pipeline injection
projects
By January 1, 2018
ARB develops a pilot financial mechanism to reduce LCFS
credit value uncertainty from dairy-related projects and
makes recommendations to the Legislature to expand the
mechanism to other biogas sources
By January 1, 2018
ARB provides guidance on the impact of regulations on
LCFS credits and compliance offsets
By January 1, 2018
ARB, in consultation with CPUC and CEC, develops policies
to encourage development of infrastructure and biomethane
projects at dairy and livestock operations
By January 1, 2018
ARB, in consultation with CDFA, evaluates the feasibility of
enteric fermentation methane reduction incentives and
regulations and develops regulations as appropriate
Ongoing
72 March 14, 2017
Action
Deadline
ARB, in consultation with CDFA, analyzes and reports on
the methane reduction progress of the dairy and livestock
sector
By July 1, 2020
ARB begins developing and considers for adoption a
manure management methane reduction regulation
Before January 1, 2024
ARB implements a manure management methane reduction
regulation
On or after January 1, 2024
3. Landfills
Landfilling organic materials leads to the anaerobic breakdown of these materials into
methane, which can work its way out of the landfill as a fugitive emission. Organic
waste constitutes a significant portion of California’s waste stream, and as with dairy
manure, a holistic approach is needed to effectively divert and manage it. This means
not only keeping organics out of landfills, either through source reduction or recycling,
but also improving the infrastructure for diverting and/or recycling organics, including
minimizing and recovering edible food wastes; and fostering composting, anaerobic
digestion and other processes for energy recovery. In particular, California must have
enough in-state composting and in-vessel digestion or other organics processing and
recycling capacity to maximize the benefits from this waste stream and effectively
minimize the spreading of unprocessed organic waste on open lands, which can have
adverse environmental impacts. It also means having markets for this material that are
robust and resilient whether as food rescue/recovery, compost, soil amendments,
mulch for erosion control, transportation fuels, energy, or other uses. The State can
accelerate progress by providing more consistent financial and institutional support for
these efforts, and taking steps to align tipping fees, financial incentives, and cross-
media regulatory structures in the sector with its organics diversion goals.
Diverting organic wastes can provide a variety of environmental and economic
benefits. Food recovery is the practice of using edible foods that would otherwise go to
waste from restaurants, grocery stores, dining facilities, food packing facilities, and
produce markets, and distributing it to local food programs. Food recovered from
farms, which would otherwise be plowed under, is typically gathered by volunteers.
The main benefit of edible food recovery programs is that they provide healthy foods to
those in need, but they also reduce organic waste disposal. Food wastes that may not
be easily used for human consumption may alternatively be used as animal feed if it
meets all regulatory requirements. Composting returns nutrients to the soil, builds soil
organic matter, improves water holding capacity, increases carbon sequestration in the
landscape, and avoids the use of fossil fuel-intense inorganic fertilizers. Anaerobic
digestion can support the State’s efforts to obtain at least 50 percent of its electricity
from renewable resources, aid in reducing the carbon intensity of transportation fuels,
and displace fossil natural gas consumption. As described in Chapter II, significantly
reducing the disposal of organics in landfills as part of a broad effort to put California’s
organic waste streams to beneficial use can generate thousands of jobs and provide
73 March 14, 2017
billions of dollars in value, much of it concentrated in the Central Valley and other rural
areas.
Eliminating the disposal of organics in landfills would align California with a growing
range of efforts to do so in other states and countries. In California, San Francisco and
Alameda County require that food waste be separated and kept out of the landfill, and
both Los Angeles and San Francisco, along with other cities, have plans in place to
achieve zero-waste.
The State has already established its intent to phase out the disposal of organics from
landfills. Existing law sets a goal to source reduce, recycle, or compost 75 percent of
solid waste by 2020 and provides other measures and requirements to support
diverting organics from landfills. California will build on that intent and progress, with
market and institutional support, and reduce disposal of organics by 50 percent of 2014
levels by 2020 and 75 percent by 2025. Due to the multi-year timeframe required to
breakdown landfilled organic material, emissions avoided by diverting organic material
in one year are realized over several decades to come. These actions would reduce
landfill emissions by 4 MMTCO
2
e in 2030,
126
but one year of waste diversion in 2030 is
expected to avoid 14 MMTCO2e of emissions over the lifetime of waste decomposition.
Still, waste-in-place will continue to emit methane for decades to come. California has
a Landfill Regulation in place that requires owners and operators of certain
uncontrolled municipal solid waste landfills to install gas collection and control systems.
This effort has improved management of landfills in California and reduced methane
emissions. There may be additional opportunities to employ best practices and further
reduce methane emissions from landfills over time.
However, quantifying emissions from landfills is difficult, due to their area-wide nature
and several landfill-specific factors (size, age, materials deposited, local atmospheric
conditions, soils, landfill cover, and gas collection system). In the GHG inventory, and
its climate programs, ARB assumes a methane capture efficiency of 75 percent at
landfills. This conforms with common practice nationally. In its Landfill Regulation,
ARB estimated that the landfill regulation may increase the collection efficiency at
regulated landfills to 80-85 percent.
126
Methane emission reductions from landfills (Table 8) are calculated assuming regulated landfills
achieve methane capture efficiencies of 80 percent by 2030, and that an annual organics tonnage
amount equal to 50 percent of the organics deposited in landfills in 2014 is diverted from the organics
waste stream sent to landfills by 2020, and an annual organics tonnage amount equal to 75 percent of
the organics deposited in landfills in 2014 is diverted from the organics waste stream sent to landfills by
2025 (i.e, meeting the organics diversion targets identified in this SLCP Strategy). The economic
analysis for this measure (See Chapter VIII) relies upon existing definitions of what types of materials
are considered organics; however, the methane emission reductions are calculated with organics
defined as all biodegradable waste. CalRecycle, in consultation with ARB and stakeholders, will be
establishing a definition of organics that is specific to addressing the novel requirements of SB 1383.
Therefore, achieving the targets may require the diversion of additional materials than those presented
in the economic analysis.
74 March 14, 2017
Estimates of methane collection efficiency at landfills vary widely. In the U.S. EPA
landfill database, the weighted average of collection efficiencies at California landfills is
78 percent.
127
However, this data is self-reported and the emission estimation method
does not incorporate emission changes due to California’s regulation. Additionally,
various studies suggest that California’s methane inventory is underestimating
methane emissions in the State. The source(s) of potential incremental methane
emissions has not been identified. Continuing evaluation of major sources of methane
in the State is necessary, and this includes landfill emissions.
The State is currently pursuing research opportunities to improve understanding of
emissions from landfills and landfill gas collection efficiencies, and will engage
stakeholders in potential opportunities to further control emissions from landfills in the
future. Once more is understood about emissions from California’s diverse set of
landfills, ARB may update the assumptions regarding collection efficiency used in its
inventory and various programs and consider whether additional actions, including a
“phase 2” of the landfill regulation, would deliver further cost-effective GHG emission
reductions.
Uncertainty around landfill emissions does not suggest that the existing Landfill
Regulation is not reducing emissions or that steps to divert organics from landfills
should be delayed. To the contrary, what is certain is that best management practices
at landfills reduce methane emissions, diverting organics from landfills can provide a
wide range of economic and environmental benefits in California, and that doing so is
the only reliable way to avoid methane emissions from landfills on a lasting basis.
The State will take the following actions to reduce methane emissions from landfills in
California:
Require Organics Diversion from Landfills
CalRecycle, in consultation with ARB, will develop regulations to reduce disposal of
organic waste by 50 percent of 2014 levels by 2020 and 75 percent by 2025, as
required by SB 1383. These regulations shall take effect on or after January 1, 2022.
CalRecycle is planning to adopt the regulations by the end of 2018, so that regulated
entities (e.g., jurisdictions, generators, facilities and haulers) have a long lead time to
plan budgetary and programmatic changes that will be needed to meet the
requirements effective in 2022. Of the edible food in the organic waste stream, not
less than 20 percent is to be recovered to feed people in need by 2025. This goal
could be met through local food waste prevention and recovery programs, which may
be independent of or through partnerships with haulers and jurisdictions. The
regulations also will cover this provision. Food waste prevention includes activities
such as education regarding food preparation and storage, refining food purchasing
practices, and software that can help inform food ordering and menu
127
The average collection efficiency at California landfills in 2013, according to EPA’s database is
76 percent. When weighted by methane generation, the average is 78 percent.
http://www3.epa.gov/airtoxics/landfill/landflpg.html
75 March 14, 2017
selections. Recovery includes local
organizations such as homeless
shelters, food banks, and community
kitchens that provide food for people
in need.
Material that cannot be effectively
recovered would be diverted to
organics recycling facilities to make
useful products, including compost,
fertilizer, fuel or energy. These
facilities may be developed at
existing landfills, other waste
management sites, or at new stand-
alone sites. Some organic wastes
could also be diverted to regional wastewater treatment plants or dairies that have
excess capacity for co-digestion. Local governments must play an important role in
diverting organics both as land use and permitting authorities for recycling facilities and
as partners in implementing SB 1383 and other statutory requirements. The State will
work with its local partners to explore development of helpful tools such as
programmatic EIRs or guidance documents. Community engagement, outreach and
education in the planning and environmental review processes are critical, both for
understanding and mitigating potential negative health and environmental impacts and
for understanding the positive economic and health and environmental benefits
afforded by such projects.
Align Financial Incentives with Organics Diversion
Eliminating organics disposal in landfill will require additional infrastructure capacity to
process and reuse diverted organic waste destined for landfills—through composting
(including chipping and grinding), anaerobic digestion, or other methods. Continued,
increased State funding is critical to building this necessary infrastructure. An
increase in California’s Integrated Waste Management Fee is also needed to support
the establishment of edible food recovery programs, discourage the landfilling of
organic waste and other recyclables, and provide funding to support organics recycling
infrastructure and markets. CalRecycle estimates that State support of at least
$100 million per year for five years, in the form of grants, loans, or incentive payments,
will be needed to leverage private sector financing and local rate structure changes to
support the development of necessary organic infrastructure and help to foster
markets. However, as disposal in landfills decreases per the goals of this SLCP
Strategy, so too would the funding from the Integrate Waste Management Fee. One
option for stabilizing funding would be to establish a charge for waste generation,
decoupling funding from landfill disposal.
76 March 14, 2017
Collaborate to Overcome Barriers
State agencies, including the AB 1045 working group and the Interagency Waste
Working Group, are currently collaborating to evaluate and resolve existing constraints
in the planning, siting, and permitting process, to provide clear standards and
compliance pathways for all public health and environmental goals, and to quantify co-
benefits. The beneficial use of methane produced at organic waste processing
facilities faces many of the same obstacles described for dairy manure or wastewater
treatment, and working groups are collaborating to address barriers to beneficial use of
organic waste streams. Also, appropriate standards should be developed to guide the
direct application of organic materials on land and ensure this activity does not pose a
threat to human or environmental health.
Foster Recovery Programs and Markets
CalRecycle will work collaboratively with other agencies and departments to help
establish edible food recovery programs and to identify, develop, and expand markets
for the use of compost, mulch, and renewable fuels and energy. CalRecycle and
CDFA will continue their efforts to incentivize the use of compost on agricultural lands
in support of the Healthy Soils Initiative, including developing best management
practices for agricultural use. They will also work with the State Water Resources
Control Board to evaluate potential mechanisms to account for the use of compost and
its impacts on nitrogen budgets in the Irrigated Lands Program as well as the potential
impacts of land application of uncomposted organic materials. CalRecycle will work
towards strengthening State procurement requirements relative to use of recycled
organic products. Finally, building on the existing use of mulch and compost as a
water conservation practice that is essential for climate adaptation with respect to
drought, State agencies will support research to quantify strategic water conservation
(e.g., seasonal groundwater recharge) and other potential benefits and consider
developing mechanisms to account for and value them. If new funding sources are
developed, as described above, then CalRecycle could also develop an incentive
payment program to overcome the marginal costs associated with most beneficial end-
uses of organics.
Improve Understanding of Landfill Emissions
ARB and CalRecycle are currently pursuing research opportunities to improve
understanding of emissions from California landfills and landfill gas collection
efficiencies and will support future research to identify opportunities to further reduce
emissions from existing waste-in-place. ARB will consider the latest science and
whether adjustments to emissions accounting in the inventory or other programs is
warranted. Based on this information, ARB, in collaboration with CalRecycle, may
consider additional actions to further reduce and capture methane emissions from
landfills in the future.
77 March 14, 2017
Evaluate Progress towards Organic Diversion Goals
To evaluate progress towards meeting the 2020 and 2025 organics waste reduction
goals, CalRecycle, in consultation with ARB, will complete a detailed analysis by July
1, 2020. This analysis will evaluate:
The status of new organics infrastructure development;
The status of efforts to reduce regulatory barriers to the siting of organics
recycling facilities;
The effectiveness of policies aimed at facilitating the permitting of organics
recycling infrastructure; and
The status of markets for products generated by organics recycling facilities.
The analysis may result in making additional requirements and/or incentives in the
regulations, as required by SB 1383.
4. Wastewater Treatment and other Miscellaneous Sources
Wastewater treatment, industrial operations, rice cultivation, septic tanks, and other
sources of methane account for about nine percent of the State’s methane inventory.
Wastewater treatment plants provide a promising complementary opportunity to help
divert a portion of organic wastes from landfills and create useful byproducts such as
electricity, biofuels, fertilizers, and soil amendments. Wastewater treatment plants are
designed to remove contaminants from wastewater, primarily from household sewage,
but with infrastructure improvements could
increase acceptance of food waste and fats,
oils, and grease (FOG) for co-digestion.
Anaerobic digestion is a typical part of the
wastewater treatment process employed at
most of the larger plants, with many plants
capturing the methane they currently generate
for on-site heating or electricity needs.
Many of these plants may have spare
capacity, and can potentially take in additional
sources of organic waste for anaerobic
digestion. Existing or new digesters at these facilities can be designed to co-digest
materials such as food waste and FOG from residential, commercial, or industrial
facilities. Many of the largest plants are ideally located close to population centers and
could potentially obtain and process significant amounts of food and other suitable
waste streams within the region. The State proposes to take the following actions to
evaluate this opportunity:
78 March 14, 2017
Develop Regional Opportunities to Co-Digest Waste
ARB will work with CalRecycle, the State Water Resources Control Board, Regional
Water Quality Control Boards, and others to determine opportunities to support the co-
digestion of food-related waste streams at existing and new digester facilities, including
wastewater treatment plants.
Align Financial Incentives with Methane Capture and Reuse at Wastewater
Treatment Facilities
A program that relies on financial incentives and/or regulatory actions could be
implemented to ensure that new and existing wastewater treatment plants in California
fully implement methane capture systems (ideally to produce on-site renewable
electricity, transportation fuel, or pipeline biogas), and maximize digestion of regional
organic materials. The potential actions would need to be tailored to each wastewater
treatment plant based on size or capacity, and other factors such as potential for co-
digestion expansion, proximity of organic waste streams, and regional air quality
standards and rules. The Water Boards could develop permit terms and other
regulatory tools to support the program while achieving water supply, water quality, and
related co-benefits.
Collaborate to Overcome Barriers
Many wastewater treatment plants are permitted to burn digester biogas through flaring
and are classified as industrial facilities. Capturing the biogas to produce electricity,
such as through a combined heat and power (CHP) system may result in re-classifying
the facility’s purpose as “electricity generation” and subject the plant to more onerous
emission compliance and abatement equipment rules. In addition, the beneficial use of
methane generated at wastewater treatment facilities faces many of the same hurdles
faced by dairy digesters and organic waste composting facilities. Support for
technologies and strategies to capture biogas to generate electricity, supplement
natural gas pipeline fuel, or for use as a transportation fuel, is needed to overcome
some of these barriers and may open up more valuable fuel and credit markets. ARB
will work with other relevant State and local agencies to identify and remove financial
and regulatory barriers that hinder the productive use of waste streams processed at
wastewater treatment plants.
5. Oil and Gas
California has a large oil and gas industry with more than 50,000 active oil wells,
including off shore platforms, about 1,500 active natural gas wells and nearly 500
underground natural gas storage wells. The majority of the oil wells are located in
Southern California with most of the gas fields located in Northern California. An
extensive network of oil and gas pipelines within the State transport California’s crude
oil from import terminals and on- and off-shore oil fields to refineries, and distributes
finished fuels to more than 70 product terminals throughout the State.
79 March 14, 2017
California also has about 215,000 miles of natural gas transmission and distribution
pipelines; 22 compressor stations; and 25,000 metering and regulating stations (M&R)
stations. Natural gas is currently California’s largest source of fuel for electricity
generation, and supplies most of the energy used for industrial operations. Natural gas
is also a primary source of energy used for residential and commercial space heating
and cooking, and represents the primary source of GHG emissions from the residential
and commercial sectors.
Much of the equipment in the oil and gas industry has been regulated for decades by
the local air districts. The districts have rules and regulations to limit VOC and NO
x
emissions because they are precursors of ground-level ozone. Many of the VOC
controls also reduce methane as a co-benefit. In 2015, U.S. EPA proposed additional
federal measures that could address methane primarily at new oil and natural gas
sources, with coverage at some existing sources. Additional actions to reduce
methane from the oil and gas sector will also reduce VOC and toxic air contaminant
emissions.
California has an emerging, comprehensive framework in place to reduce methane
emissions from oil and gas infrastructure. Effectively implementing this framework can
reduce methane emissions from oil and gas systems by 40-45 percent in 2025,
matching federal commitments.
128
Additional opportunities may emerge to further
reduce emissions from infrastructure and will be considered when they do. But further
reducing methane emissions from the oil and gas sector will ultimately require reducing
in-state demand. A rapid decline for demand for oil and natural gas is also necessary
to meet the State’s 2030 and 2050 climate targets, more broadly.
About 90 percent of California’s natural gas comes from out of State, and ultimately,
action by other jurisdictions is needed to minimize leaks associated with our natural
gas use. The federal government has taken steps to address oil and gas sector
methane emissions, especially at the point of production, but more may need to be
done to reduce emissions from pipelines and other equipment out-of-state. There may
be steps that California agencies or utilities can take to ensure that infrastructure
supplying gas to the state has minimal leakage, and to ensure that natural gas is
providing environmental benefits compared to use of other fossil fuels in the State.
The State’s framework on oil and gas methane emissions includes the following
elements:
Adopt and Implement a Regulation for Greenhouse Gas Emission Standards for
Crude Oil and Natural Gas Facilities
In July 2016, the Board directed staff to continue working with local air districts and
other stakeholders to develop a regulation for final Board consideration by early 2017.
The proposed regulation will require:
128
For the purposes of calculating emission reductions in 2030, Table 8 assumes a 45 percent reduction
below current levels by 2030.
80 March 14, 2017
Vapor collection on uncontrolled oil and water separators and storage tanks with
emissions above a set methane standard;
Vapor collection on all uncontrolled well stimulation circulation tanks, pending a
technology assessment;
Leak Detection and Repair (LDAR) on components, such as valves, flanges,
and connectors, currently not covered by local air district rules;
Vapor collection of large reciprocating compressors’ vent gas, or require repair
of the compressor when it is leaking above a set emission flow rate;
Vapor collection of centrifugal compressor vent gas, or replacement of higher
emitting “wet seals” with lower emitting “dry seals”;
“No bleed” pneumatic devices and pumps; and
Ambient methane monitoring and more frequent well head methane monitoring
at underground natural gas storage facilities.
This regulation would build upon some existing air districts’ volatile organic compound
based rules and include additional areas and infrastructure components (such as
valves, flanges, and seals) that are not currently covered by local district programs.
ARB staff is proposing a regulatory approach to ensure that any combustion-based
controls will not interfere with efforts to achieve and maintain compliance with ambient
air quality standards in cases where methane and VOC emissions cannot be sent into
existing sales lines, fuel lines, or reinjection wells, and are instead captured by
installing new vapor collection on existing storage tanks, with the collected vapors
being sent to a low-NOx incinerator that will replace an existing, higher-NOx emitting
flare.
Improve Monitoring and Standards to Detect and Minimize Emissions
ARB and DOGGR are working together to ensure that both above and below ground
monitoring of storage facilities is improved. As mentioned above, ARB is proposing
improved above-ground methane monitoring of underground storage facilities in its
upcoming Oil and Gas Production, Processing, and Storage Regulation. Some of the
features of this provision implement SB 887 (Health and Safety Code section 42710).
In February 2016, DOGGR adopted emergency regulations to implement protective
standards specifically designed to ensure that operators of underground gas storage
facilities are properly minimizing risks and taking all appropriate steps to prevent
uncontrolled releases, blowouts, and other infrastructure-related accidents. The
emergency regulations will ensure that operators of existing underground gas storage
facilities monitor for and report leaks to DOGGR, function test all safety valve systems,
perform inspections of wellheads and surrounding area and equipment, develop risk
management plans that require verification of mechanical integrity and corrosion
assessment and monitoring, and provide DOGGR with complete project data and risk
assessment results. In July 2016 DOGGR released a pre-rulemaking draft that will
replace its emergency rulemaking. The discussion draft contains much of the content
included in the emergency rulemaking with the addition of, among other things, stricter
well construction standards and mechanical integrity testing requirements to reduce the
81 March 14, 2017
risk of wells leaking. DOGGR anticipates that the formal rulemaking process will
conclude in 2017. Immediate implementation of these standards will ensure that
underground gas storage facilities are properly operated, minimizing the potential that
an incident such as the gas leak at the Aliso Canyon Natural Gas Storage Facility does
not recur.
129
ARB and DOGGR will coordinate on the monitoring provisions to ensure
consistency and comprehensiveness while limiting duplication.
Additionally, Assembly Bill 1496 requires ARB, in consultation with scientific experts
and other state, local, and federal agencies, to undertake monitoring and
measurements of high-emission methane “hot spots” and conduct lifecycle GHG
emission analysis for natural gas produced in and imported into California. Pursuant to
this bill, ARB will continue its efforts related to hot spots monitoring and lifecycle
greenhouse gas accounting for fuels, and hosted a scientific workshop in June 2016 to
collect the best available knowledge on these topics. ARB will update relevant policies
and programs to incorporate any new information gathered as a result of these efforts.
Effectively Implement SB 1371 to Reduce Emissions from Pipelines
Senate Bill 1371 (Leno, Chapter 525, Statutes of 2014) directs the CPUC, in
consultation with ARB, to adopt rules and procedures to minimize natural gas leaks
from CPUC-regulated intrastate transmission and distribution gas pipelines and
facilities. Among other requirements, SB 1371 directs the CPUC to adopt rules and
procedures that provide for the maximum technologically feasible and cost-effective
avoidance, reduction, and repair of leaks and leaking components. In January 2015,
the CPUC launched a rulemaking proceeding (R.15-01-008) to carry out the intent of
SB 1371. Under this proceeding, CPUC published a report that identifies new gas leak
detection technologies that can be used to optimize methane reductions from
transmission, distribution, and storage processes. CPUC also required utility
companies and gas suppliers to report natural gas emission data annually and best
leak management practices. To date, the industry has submitted two consecutive
emission inventories in 2015 and 2016, respectively. In June 2015, CPUC conducted
a prehearing conference to discuss the draft scoping memo of relevant topics to be
deliberated during the 24-month timeframe of the proceeding. In addition, several
public workshops and workgroup meetings have been held in San Francisco and
Sacramento.
ARB continues to actively participate in the proceeding and will lead efforts to analyze
collected utility emission data, develop quantification protocols, and identify potential
mitigation strategies. In particular, ARB will focus on the emission reduction potential
of the proceeding in keeping with the objectives of AB 32 as they pertain to:
129
Preliminary estimates suggest the incident resulted in about 8 MMTCO
2
e (AR5 20-year GWP) of
methane emissions, an approximately 20 percent increase in statewide methane emissions for the
duration of the leak (October 23, 2015–February 17, 2016). Governor Brown's January 2016 Aliso
Canyon Proclamation directs the ARB to develop a mitigation plan for the leaked methane emissions by
March 31, 2016. It can be accessed at:
http://www.arb.ca.gov/research/aliso_canyon/arb_aliso_canyon_methane_leak_climate_impacts_mitigati
on_program.pdf
82 March 14, 2017
Comparing the data collected under SB 1371 with the Mandatory Reporting
Regulation;
Analyzing emission data to determine potential mitigation strategies. For
example, the proceeding may require the replacement of older pipelines or
pipelines constructed of a certain material;
Identifying any remaining data gaps;
Establishing procedures for the development and use of metrics to quantify
emissions;
Reviewing and evaluating the effectiveness of existing practices for the
operation, maintenance, repair, and replacement of natural gas pipeline facilities
to determine the potential to reduce methane leaks and where alternative
practices may be required;
Provide input on cost-effectiveness; and
Funding studies to update emission factors from important leak sources, such
as pipelines and customer meters.
The final decision on potential rules and procedures by the CPUC, including
ratemaking and financial incentives to minimize gas leaks, is anticipated in the fall of
2017. Upon evaluation of the industry’s compliance with the decision, ARB will
determine whether additional regulatory actions or incentives are required to further
reduce methane emissions from this source.
83 March 14, 2017
VI. Reducing HFC Emissions
Hydrofluorocarbons (HFCs) are the fastest-growing source of GHG emissions both
globally and in California. HFCs are fluorinated gases (F-gases), which also include
the ozone-depleting substances (ODS) that are being phased out under the Montreal
Protocol. HFCs currently comprise four percent of all GHG emissions in California, and
without a phasedown and additional emission reduction measures, annual HFC
emissions would increase 60 percent under business-as-usual by 2030 as HFCs
continue to replace ODS (Figure 6).
Figure 6: Emission Trends of ODS and ODS substitutes (hydrofluorocarbons) –
(as ODS are phased out, HFCs increase).*
* Further analysis is needed to reflect the impact of the Kigali Amendment on HFC emission reductions
in California
The majority of HFC emissions come from fugitive emissions of refrigerants used in
refrigeration and air-conditioning (AC) systems. The largest uses of HFCs are in
commercial and industrial refrigeration and air-conditioning, which comprise 48 percent
of HFC emissions. More than half of refrigeration and air-conditioning equipment
currently uses HCFC-22, a high-GWP ODS which is scheduled for a complete phase-
out of new production and import in the U.S. by 2020. The HCFC-22 refrigerant is
being replaced with HFCs that have higher GWPs, thus increasing the GHG impact of
refrigerants. We expect that in anticipation of the HCFC-22 phase-out by 2020, most
owners of equipment using HCFC-22 will either replace the equipment by 2020, or at a
minimum replace the HCFC-22 refrigerant in the same equipment (retrofit) with a high-
GWP HFC refrigerant. A window of opportunity exists in the next five years to
accelerate the transition of refrigeration and air-conditioning equipment to lower-GWP
refrigerants, before another generation of equipment is locked into using higher-GWP
refrigerants over their average lifetimes of 15 to 20 years.
84 March 14, 2017
HFC emissions from transportation are largely from mobile vehicle air-conditioning
(MVAC), and as California and the U.S. EPA implement the MVAC credits programs
under their light-duty vehicle GHG emission standards, and the MVAC leakage
standards under their heavy-duty vehicle GHG emission standards, the share of HFC
emissions from the transportation sector will decline. Aerosol propellants (industrial,
consumer, and medical dose inhalers) comprise 13 percent of HFC emissions, and
insulating foam expansion agents contribute another eight percent of HFC emissions.
Solvents and fire suppressant emissions contribute one percent of all HFC emissions.
Figure 7 shows the emissions sectors that contribute to California's overall HFC
emissions. (ODS emissions are not shown because they are being completely phased
out under the Montreal Protocol and are not included in the AB 32 GHG emission
reduction targets.)
Figure 7: California 2013 Hydrofluorocarbons (HFCs) Emission Sources*
*Using 20-year GWP
This SLCP Strategy identifies measures that can reduce HFC emissions by 40 percent
in California by 2030. They represent a reasonable path forward for California, and will
complement the global HFC supply phasedown, agreed to in October 2016. Although
the global phasedown will result in significant HFC emission reductions, the
phasedown by itself will not be sufficient for California to reach the 40 percent HFC
emission reduction goal by 2030.
A. Progress to Date
California is among the world’s leaders in reducing HFCs and other F-gas emissions.
Measures adopted under AB 32 have reduced emissions from a variety of sources.
The State's Cap-and-Trade offset protocol for ozone depleting substances incentivizes
the capture and destruction of ODS refrigerants and foam expansion agents. The
biggest reductions of high-GWP F-gases are coming from ARB’s Refrigerant
Management Program, which requires facilities with refrigeration systems to inspect
and repair leaks, maintain service records, and in some cases, report refrigerant use.
The Refrigerant Management Program has helped change industry practices to
become more proactive in preventing refrigerant leaks, which has helped businesses
save money by avoiding system repairs and downtime as well as the cost of
replacement refrigerant. Other measures already in place include low-GWP
requirements for consumer product aerosol propellants and a self-sealing valve
85 March 14, 2017
requirement for small cans of automotive refrigerants purchased by “do-it-yourself”
mechanics.
California’s efforts to reduce emissions of F-gases are part of a broader set of national
and international commitments.
A Global Phasedown in HFC Production and Consumption
On October 15, 2016, an historic agreement was reached in Kigali, Rwanda, by nearly
200 countries to adopt a global phasedown in the production and consumption of
HFCs. The international agreement was an outcome of the 28
th
Meeting of the Parties
to the Montreal Protocol, the 1987 agreement that initiated a phase-out of ODS. The
HFC phasedown agreement is expected to prevent up to 0.5 degrees Celsius of global
warming by the end of this century.
Developed countries must begin to phasedown HFC production and consumption in
2019, with an increasing cap until only 15 percent of production and consumption
remains by 2036. Developing countries will begin a phasedown in 2029, and
developing countries in hot ambient climates will have until 2032 to begin a
phasedown. The phasedown schedule is shown in Table 10 below:
86 March 14, 2017
Table 10: Global HFC Production/Consumption Cap*
Phasedown Schedule
Year
Developed
Countries
Developing
Countries
Group 1
Developing
Countries
Group 2**
2017-2018
No Freeze
2019
90%
2024
60%
Freeze
2028
Freeze
2029
30%
90%
2032
90%
2034
20%
2035
70%
2036
15%
2037
80%
2040
50%
2042
70%
2045
20%
2047
15%
* The baseline to calculate a production/consumption cap for developed countries is the annual average
of HFC consumption (CO
2
-equivalents) in 2011, 2012, and 2013, plus 15 percent of the annual average
consumption of HCFCs in 2011-2013.
**Group 2 countries include the Gulf Coast Countries (Saudi Arabia, Kuwait, the United Arab Emirates,
Qatar, Bahrain, and Oman), India, Iran, Iraq, and Pakistan.
The phasedown schedule is also shown in graph form in Figure 8 below.
87 March 14, 2017
Figure 8: Global HFC Phasedown Schedule for the Three Groups of Countries
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2017 2022 2027 2032 2037 2042 2047
HFC Consumption compared to baseline
Developed
Countries
Consumption Cap
Developing
Countries (Group 1)
Consumption Cap
Developing
Countries (Group 2:
Gulf Coast
Countries, India,
Iran, Iraq, Pakistan)
Consumption Cap
As shown by the successful ODS phase-out, an HFC phasedown allows industry the
flexibility to make market-based decisions on when and where to continue to use
high-GWP HFCs before transitioning to lower-GWP options.
Additional State, National, and International Efforts to Reduce HFC Emissions
In addition to the Kigali Amendment to phasedown HFC production and consumption
globally, other developments in the U.S. and internationally will further reduce HFC
emissions as described below. The U.S. EPA can impose federal bans on F-gases
under the Significant New Alternatives Policy (SNAP) Program. In July 2015, the U.S.
EPA adopted future bans on specific HFCs with very high GWPs used in new
commercial refrigeration systems, the manufacture of polyurethane foam, and new
light-duty motor vehicle air-conditioning systems.
130
In many cases, these national
bans copied programs that were first demonstrated in California. The U.S. national
bans are expected to decrease HFC emissions in California by ten percent annually
below business as usual by 2025. The European Union (EU) has adopted the world’s
130
Protection of Stratospheric Ozone: Change of Listing Status for Certain Substitutes Under the
Significant New Alternatives Policy Program; Final Rule. Federal Register. Volume 80, Number 138,
Monday, July 20, 2015. Part II. Environmental Protection Agency. 40 CFR Part
82. http://www.epa.gov/ozone/snap/regulations.html
88 March 14, 2017
leading F-gas regulation that will phase down the production and import of HFCs by
almost 80 percent from 2014 levels by 2030.
131
,
132
Additionally, in response to the federal Climate Action Plan, in September 2014, and
again in October 2015, the private sector made commitments and executive actions
were taken to reduce emissions of hydrofluorocarbons (HFCs).
133
,
134
U.S. industry is
leading the way by investing billions of dollars to develop and deploy the next
generation of HFC alternatives that are safer for the environment. These investments
span the entire HFC supply chain—from where the chemicals are produced, to where
they are used in manufacturing, to where consumers see them in stores.
Further private sector commitments were made in February 2016, when both the Air
Conditioning Heating & Refrigeration Institute (AHRI) and the Association of Home
Appliance Manufacturers (AHAM) made voluntary commitments to phase down the use
of high-GWP HFCs in new equipment.
135
,
136
In March 2016, the U.S. EPA proposed additional bans on high-GWP HFCs in new
retail food refrigeration, cold storage, chillers used for air-conditioning, and household
refrigerator-freezers.
137
The proposal was adopted in September 2016.
In July 2016, ARB and CEC committed $500,000 to fund the completion of a research
project to assess the feasibility and safety of low-GWP refrigerants, adding to the
existing $5.3 million venture research funded by the Department of Energy (DOE), the
AHRI, and the American Society of Heating, Refrigerating and Air-Conditioning
Engineers (ASHRAE). A goal of the study is to accelerate research and consideration
131
Velders et al (2014) “Growth of climate change commitments from HFC banks and emissions”, G. J.
M. Velders, S. Solomon, and J. S. Daniel. Atmospheric Chemistry and Physics, 14, 4563–4572, 2014.
doi:10.5194/acp-14-4563-2014. www.atmos-chem-phys.net/14/4563/2014/.
132
EC (2014) European Commission (EC), April 16, 2006 “Regulation (EU) No 517/2014 of the
European Parliament and of the Council on fluorinated greenhouse gases and repealing Regulation (EC)
No 842/2006”. http://ec.europa.eu/clima/policies/f-gas/legislation/documentation_en.htm
133
Fact Sheet: Obama Administration Partners with Private Sector on New Commitments to Slash
Emissions of Potent Greenhouse Gases and Catalyze Global HFC Phase Down. September 16, 2014:
http://www.igsd.org/documents/20140916HFCFactSheet.pdf
134
Fact Sheet: Obama Administration and Private-Sector Leaders Announce Ambitious Commitments
and Robust Progress to Address Potent Greenhouse Gases. October 15, 2015.
https://www.whitehouse.gov/the-press-office/2015/10/15/fact-sheet-obama-administration-and-private-
sector-leaders-announce.
135
AHRI and Natural Resources Defense Council (NRDC) February 1, 2016 petition to U.S. EPA
Significant New Alternatives Policy (SNAP) Program to remove high-GWP HFCs from the list of
acceptable substitutes in new air-cooled and water-cooled chillers using centrifugal, screw, scroll, and all
other compressor types.
136
“Home Appliance Industry Sets Goal to Eliminate Use of HFC Refrigerants”, Press Release February
9, 2016 from Association of Home Appliance Manufacturers (AHAM). http://www.prnewswire.com/news-
releases/home-appliance-industry-sets-goal-to-eliminate-use-of-hfc-refrigerants-300217501.html.
137
Fact Sheet. Proposed Rule ‐ Protection of Stratospheric Ozone: New Listings of Substitutes;
Changes of Listing Status; Reinterpretation of Unacceptability for Closed Cell Foam Products under the
Significant New Alternatives Policy Program; and Revision of Clean Air Act Section 608’s Venting
Prohibition for Propane. U.S. EPA, March 29, 2016. https://www.epa.gov/snap/snap-regulations
89 March 14, 2017
by these bodies by up to three years sooner than the normal deliberative pace of
standards and codes research. Commercial refrigeration and air conditioning are
included in the research project, while domestic refrigeration is not within the project
scope. The project is on an aggressive, tiered schedule to assess the safety of mildly
flammable and flammable refrigerants, in order to update building codes and safety
standards.
138
The study is critical for national and international HFC mitigation policies
and will accelerate the time frame for low-GWP refrigerants that are necessary for the
California to meet its SLCP emission reduction goals.
Substantial progress has also been made to safely use natural refrigerants (such as
CO
2
, ammonia [NH
3
], and hydrocarbons [HCs]), with GWPs at or near zero) all over
the world, especially in Europe and Asia. The refrigeration and air-conditioning
industry is looking closely at which applications suit which natural refrigerants. Reports
summarizing the progress made in North America show nearly 300,000 pieces of light
commercial equipment using CO
2
or hydrocarbons, more than 250 stores using CO
2
systems, and over 250 “next-generation” small-charge ammonia systems in industrial
installations. Large companies investing in natural refrigerants include end users, and
a wide range of equipment manufacturers.
In addition to the natural refrigerants, a new generation of fluorinated refrigerants
known as hydrofluoro-olefins (HFOs) have been developed that are non-ODS and
have GWP values less than six. HFOs can be used in pure form for some cooling
applications, such as motor vehicle AC, and are also used in blends with HFCs for
other cooling applications, such as commercial and industrial refrigeration. Initial
results indicate that the newest generation of fluorinated refrigerants performs as well
as the high-GWP HFCs they replace.
These State, national, and international efforts will lead to significant reductions in HFC
emissions in California through 2030, compared to where they would be otherwise.
With the global HFC phasedown agreement in place, HFC emissions in California will
decrease significantly, but not enough to meet the reduction goal of 40 percent below
2013 levels by 2030 (Figure 9).
138
White House Office of the Press Secretary June 2, 2016, “FACT SHEET: U.S. Hosts World's Energy
Ministers to Scale Up Clean Energy and Drive Implementation of the Paris Agreement” Available at:
https://www.whitehouse.gov/the-press-office/2016/06/02/fact-sheet-us-hosts-worlds-energy-ministers-
scale-clean-energy-and-drive (accessed 2 June 2016).
90 March 14, 2017
Figure 9: California’s 2030 HFC Emission Sources with Existing Measures*
*Using 20-year GWP
B. Recommended Actions to Further Reduce HFC Emissions
The State supports strong, national, and international actions to reduce HFC
emissions. The U.S. EPA has already taken a number of steps to prohibit the use of
new high-GWP HFCs in consumer product aerosol propellants, polyurethane insulating
foam, and light-duty mobile vehicle air-conditioning. An international agreement was
reached in October 2016 to phase down the production and use of HFCs under the
Montreal Protocol. The proposed Montreal Protocol HFC phase down amendments
will reduce HFC emissions significantly by 2050.
However, if additional measures can be applied in California to achieve further GHG
emission reductions in the near-term and at low cost, California will consider them to
support the State’s 2020 and 2030 GHG targets.
For example, the State should consider developing an incentive program to encourage
the use of low-GWP refrigerants, which could lead to very low-cost emission reductions
and could be implemented while further regulations are considered or developed. This
would provide long-term avoided emissions by countering the current trend of replacing
HCFC-22, the most common refrigerant for both refrigeration and air-conditioning, with
higher-GWP HFCs. This trend is accelerating in the U.S. in response to the 2020
phase-out of HCFC-22 under the Montreal Protocol.
Even with the strong international agreement to phase down the use of HFCs, under a
best-case scenario, the currently proposed global phasedown schedule will not achieve
the reductions needed to meet the 2030 HFC emission reduction goal for California.
Therefore, additional opportunities may remain to reduce their emissions in California
in the near-term and through 2030 at low cost. Early action, ahead of some of the
phase down schedules being proposed internationally, can avoid locking-in the use of
high-GWP refrigerants in new or retrofitted systems in the coming years.
For example, as effective alternatives become available, ARB will consider developing
limitations on the use of high-GWP refrigerants in new refrigeration and air-conditioning
equipment where lower-GWP alternates are feasible and readily available. ARB will
focus on measures that can move low-GWP alternatives and technologies forward both
91 March 14, 2017
nationally and internationally. California has a wide range of climate zones from alpine
conditions to hot desert environments. As such, California could be instrumental as a
proving ground for low-GWP refrigeration and air-conditioning technologies that can be
used in extreme environments across the world.
All refrigerants and substitutes to high-GWP F-gases must first be approved by the
U.S. EPA’s SNAP Program to ensure the alternatives meet health and safety criteria.
The approval process is designed to minimize the risk of using newer alternatives to
F-gases by identifying substitutes that offer lower overall risks to human health and the
environment.
This SLCP Strategy describes a set of potential measures that can reduce HFC
emissions by 40 percent in California by 2030 (see Table 11). This set of measures
has been designed to minimize regulatory requirements and achieve fast and assured
emission reductions. Additional analysis is needed to determine the impact of the
global HFC phasedown on future HFC reductions in California. When this analysis is
complete, further evaluation will be conducted on the scope of the additional emission
reduction measures identified in Table 11.
Table 11: Proposed New HFC Emission Reduction Measures and Estimated
Emission Reductions (MMTCO
2
e)
1
Measure Name
2030 Annual
Emission
Reductions
2030 Annual
Emissions
2030 BAU
2
65
Financial Incentive for Low-
GWP Refrigeration Early
Adoption
2
HFC Supply Phasedown (to
be achieved through the
global HFC phasedown)
3
19
Prohibition on sales of very-
high GWP refrigerants
5
Prohibition on new equipment
with high-GWP Refrigerants
15
2030 BAU with new measures
24
1
Using 20-year GWPs from the 4
th
Assessment report of the IPCC
2
"Business as Usual" (BAU) forecasted inventory includes reductions from implementation
of current ARB and U.S. EPA regulations
3
A global HFC production and consumption phasedown was agreed to on October 15, 2016, in
Kigali, Rwanda. ARB is currently evaluating the impact upon HFC emission reductions in California
and plans to utilize the results from the assessment to inform future updates to BAU projections for
HFC emissions.
92 March 14, 2017
Incentive Programs
A voluntary early action measure recommended is an incentive program to defray the
potential added cost of installing new low-GWP refrigeration equipment or converting
existing high-GWP systems to lower-GWP options. This program could provide
immediate and ongoing emission reductions. A loan or grant program would support
qualifying facilities that take action to reduce emissions prior to any national or state
requirements to do so.
Data reported under the existing Refrigerant Management Program indicates that more
than 2,400 facilities with large commercial refrigeration systems in California currently
use HCFC-22 refrigerant. This refrigerant has not been allowed in new equipment
since January 2010, and all new production and import will cease by January 1, 2020.
Therefore, these facilities must either buy increasingly scarce recycled HCFC-22 to
maintain their systems, or replace or retrofit their existing systems with another
refrigerant within five years.
Although lower-GWP options are currently available and can be cost effective, in most
cases with improved energy efficiency, there are two main barriers to more widespread
adoption of low-GWP commercial refrigeration: 1) potentially higher up-front costs, and
2) lack of familiarity with low-GWP refrigeration. The incentive program could remove
the added initial cost barrier and build familiarity with low-GWP refrigeration systems to
help them scale throughout the sector.
One of the advantages of an incentive program is that it could fund early adoption of
low-GWP technologies, with substantial long-term effects on avoided emissions. The
incentive program would “lock in” early and permanent GHG emission reductions prior
to any mandatory measures.
Phasedown in Supply of HFCs
Due to the global HFC phasedown agreement, a California-specific HFC phasedown
will not be necessary if the agreement is ratified by the U.S. Although the HFC
phasedown will eventually result in significant reductions, preliminary ARB analysis
indicates that the phasedown alone is not sufficient to reach California HFC emission
reduction goals by 2030 for the following reasons:
1) The current oversupply of HFCs in the U.S. (as a result of “dumping” imports of
HFCs at less than fair market value) will ensure that the supply of HFCs is greater than
demand at the beginning of the phasedown for 2019;
2) The initial cap on HFC production and consumption is estimated to be much higher
than the demand, delaying the transition to lower-GWP alternatives, and therefore
delaying emission reductions;
139
139
ARB analysis February 2017. The HFC cap baseline will be finalized by the U.S. EPA by Jan. 2018.
93 March 14, 2017
3) Existing equipment using high-GWP HFCs has an average lifetime of 15-20 years,
and can be expected to continue operating and emitting high-GWP HFCs well past
2030. The relatively long equipment life is responsible for a long lag time of
10-20 years between a production phase-out and an equivalent emission reduction;
140
4) Without diligent national enforcement efforts by the U.S. EPA, illegal imports of
high-GWP HFCs into the U.S. from developing countries may be a significant issue, as
developing countries do not start an HFC phasedown until 2029, and imported HFCs
are likely to be much less expensive. A similar problem occurred in the U.S. in the
1990s when ozone-depleting refrigerants were banned but continued to be illegally
imported into the U.S.
141
ARB will continue to work with industry representatives to evaluate the impact of the
Kigali Amendment on HFC emissions and reductions in California, especially as they
pertain to meeting the 40 percent emission reduction goal. The assessment will be
available later in 2017 for public and scientific peer review. The results of the
assessment will be considered in future rulemaking processes. ARB will focus on
measures that can move low-GWP alternatives and technologies forward both
nationally and internationally. For example, as effective alternatives become available,
ARB will consider developing limitations on the use of high-GWP refrigerants in new
refrigeration and air-conditioning equipment where lower-GWP alternatives are feasible
and readily available. California's climate zones range from high alpine to hot desert
environments. As such, California could be instrumental as a proving ground for low-
GWP refrigeration and air-conditioning technologies that can be used in extreme
environments around the world.
Prohibition on the Sale of New Refrigerant with Very-High GWPs
This measure would prohibit the sale or distribution of refrigerants with 100-year GWP
values of 2500 or greater. Refrigerants that are certified reclaimed or recycled would
be exempt from the sales ban.
In July 2015, the U.S. EPA adopted a ban on using refrigerants with a very-high
100-year GWP of 2500 or greater in new and retrofitted refrigeration systems at retail
food facilities beginning in the second half of 2016. Several refrigerants are currently
140
Gallagher, et al., 2014. “High-global Warming Potential F-gas Emissions in California: Comparison
of Ambient-based versus Inventory-based Emission Estimates, and Implications of Estimate
Refinements”. Glenn Gallagher, Tao Zhan, Ying-Kuang Hsu, Pamela Gupta, James Pederson, Bart
Croes, Donald R. Blake, Barbara Barletta, Simone Meinardi, Paul Ashford, Arnie Vetter, Sabine Saba,
Rayan Slim, Lionel Palandre, Denis Clodic, Pamela Mathis, Mark Wagner, Julia Forgie, Harry Dwyer,
and Katy Wolf . Environmental Science and Technology 2014, 48, 1084−1093. Available at
dx.doi.org/10.1021/es403447v (accessed 28 January 2016).
141
EIA, 2005. Environmental Investigation Agency (EIA). “Under the Counter – China’s Booming Illegal
Trade in Ozone-Depleting Substances”, by Ezra Clark. December, 2005. Emerson Press, ISBN 0-
9540768-2-6. Available at: https://eia-international.org/wp-content/uploads/Under-The-Counter-Dec-
05.pdf.
94 March 14, 2017
available with a 100-year GWP of less than 1500 that can be used in existing
equipment designed for higher-GWP refrigerants.
A sales ban on very high-GWP refrigerants is enforceable and provides immediate
reductions. Such a ban facilitates a much faster transition from very high-GWP
refrigerants to lower-GWP alternatives in existing equipment (thus avoiding the
ongoing high-GWP emissions from equipment that typically lasts for 15 years or
longer).
High-GWP Refrigerant Prohibitions in New Stationary Systems
This measure would prohibit the use of high-GWP refrigerants in new commercial,
industrial, and residential stationary refrigeration and air-conditioning equipment, as
follows:
Stationary Refrigeration or Stationary Air-
Conditioning Sector
Refrigerants Prohibited in
New Equipment with a 100-
year GWP Value:*
Non-residential refrigeration
150 or greater**
Air-conditioning (non-residential and residential)
750 or greater
Residential refrigerator-freezers
150 or greater
*The need for specific GWP limits and the proposed start dates for each end-use sector will be further
evaluated as ARB assesses the impact of the global HFC phasedown agreement (Kigali Amendment) on
future HFC emissions and reductions in California.
** Does not apply to small HFC/HFO central charge (with 100-year GWP less than 1500) used in hybrid
refrigeration such as secondary loop and cascade systems.
GWP limits for specific air conditioning equipment types could be made more stringent
if low-GWP technologies develop more quickly than anticipated, such as the continued
development of low and medium-pressure air-conditioning chillers that use refrigerants
with a GWP less than 150.
Certain exceptions could be made to any maximum GWP limit if no low-GWP
refrigerants are technically feasible in a specific application. Additionally, high-GWP
prohibition dates could be extended for specific end-use sectors where codes and
standards do not allow the use of feasible low-GWP refrigerants.
In addition to current safety testing of residential appliances, significant research is
underway to assess the safety and feasibility of low-GWP refrigerants in commercial
refrigeration, commercial AC, and residential AC. While not every end-use sector has
low-GWP options commercially available today, rapid development of low-GWP
options is expected to continue.
Energy efficiency of low-GWP refrigeration and AC is one of the most important factors
in the transition from high-GWP to low-GWP technology. If energy consumption
increases, the additional GHG emissions from electricity generation will defeat the
95 March 14, 2017
purpose of the low-GWP requirements. Therefore, energy efficiencies and “energy
penalties” of low-GWP technologies are taken under consideration in the development
of HFC emission reduction measures. According to refrigerant manufacturers, the new
low-GWP synthetic refrigerant hydrofluoro-olefin (HFO) blends are as energy efficient
as the HFC refrigerants they replace. In some cases, the HFO blends exhibit better
energy efficiency than baseline HFC refrigerants. Among the “natural” refrigerants,
hydrocarbon and ammonia refrigerants exhibit well-known energy efficiencies
compared to HFC refrigerants. Carbon dioxide refrigerant is generally the same
efficiency or more energy-efficient in cooler climates, and less efficient in warmer
climates compared to HFCs. Improving the efficiency of CO
2
refrigeration in warmer
climates is currently the subject of a great deal of research and development by
equipment manufacturers. We expect the end of the “energy penalty” of CO
2
refrigeration in the next few years as equipment is designed for increasingly warmer
climate zones, including desert climates. Additional details on low-GWP refrigerants
and energy efficiency are included in Appendix F.
Low-GWP commercial refrigeration using ammonia is already extensively used in food
processing and cold storage. Additionally, more than 250 retail food stores in the U.S.
have begun using CO
2
as the primary or secondary refrigerant. In Europe, CO
2
refrigeration is used in more than 5,200 retail food stores, and generally is cost neutral
compared to HFC refrigeration systems. In the hotter climate zones of California, using
100 percent CO
2
refrigeration may not be as energy-efficient as HFC refrigerants,
although newly demonstrated
adiabatic cooling technology
has promise to neutralize
energy efficiency concerns.
Alternatively, manufacturers
are currently developing
blends of HFC refrigerants
combined with a new class of
very-low GWP synthetic
refrigerants known as
hydrofluoro-olefins (HFOs).
The HFO-HFC blends have
100-year GWPs between 88 and 1400, and their use would reduce GHGs in these
systems by more than 75 percent compared to business as usual.
142
Hybrid
refrigeration such as secondary loop and cascade systems, using a small HFC central
charge and a larger CO
2
charge, experience no energy penalty, even in hotter
climates.
With respect to air-conditioning, in September 2014, the AHRI, an industry association
representing 90 percent of U.S. air-conditioning manufacturing and 70 percent of the
global industry, made a commitment through the White House Council on
142
HFOs are hydrofluoro-olefins, an emerging class of F-gas with very low GWPs of 1-5, but which are
classified as slightly flammable (A2L). By blending HFOs with HFCs, refrigerant blends which are non-
flammable have been created and U.S. EPA SNAP-approved for certain applications.
96 March 14, 2017
Environmental Quality to spend $5 billion over the next ten years to develop low-GWP
options for refrigeration and air-conditioning. Many commercially available lower-GWP
air-conditioning options are expected by 2020. In order to comply with the EU F-gas
regulation that went into effect January 1, 2015, manufacturers are already developing
air-conditioning systems that use refrigerants with a 100-year GWP of less than 750.
Large chillers used primarily for office building air-conditioning are already
commercially available that use an HFO refrigerant with a GWP of one.
Current fire and appliance codes do not allow the use of hydrocarbon refrigerants,
which are flammable, unless the system is below a small charge size threshold of
150 grams for commercial refrigerators, and 57 grams for household refrigerators.
Experience in Europe and other jurisdictions demonstrates that these codes can be
designed to allow for the use of these refrigerants while ensuring safety, where current
limits are 150 grams for household refrigerators and up to 1.5 kg for commercial uses.
More work is required to update the safety codes in the U.S. before slightly flammable
refrigerants can be used in more applications while maintaining safety.
A prohibition, or ban on the use of high-GWP HFCs in new equipment would result in
certainty of reductions in applications where alternatives are readily available, and
immediate HFC reductions that the global phasedown would not achieve until many
years later. By requiring equipment manufacturers to sell only ARB-compliant
equipment in California, the enforcement focus is on the manufacturers and is not
placed on the end-user.
Additional measures that may be more effectively addressed at the Federal level
include prohibitions on high-GWP HFCs in the following sectors: consumer product
aerosol propellants, insulation spray foam, heavy-duty motor vehicle air-conditioning,
transport refrigeration units (TRUs), and refrigerated shipping containers. ARB will
continue to work with the U.S. EPA on reducing HFC emissions from these sectors,
and may pursue state-level measures if progress is not made on the Federal level.
C. Sulfuryl Fluoride
Sulfuryl fluoride (SO
2
F
2
) is a pesticide fumigant and one of the most common
replacements for methyl bromide, an ozone-depleting substance whose use is being
phased out. Sulfuryl fluoride is regulated by the California Department of Pesticide
Regulation (DPR), and was listed as a toxic air contaminant (TAC) in 2006. As a
pesticide and TAC, sulfuryl fluoride’s use is strictly controlled. In December 2015, DPR
submitted a report to the Legislature, which provided an update on adopted control
measures for sulfuryl fluoride,
143
as required by AB 304 (Williams, Chapter 584,
Statutes of 2013). DPR plans to develop additional mitigation measures by September
2016, to address unacceptable exposures of sulfuryl fluoride to bystanders and
143
Report to the Legislature Required by AB 3014 (2013) Food & Agricultural Code Section
140124(c)(2)(A): Update on the Adoption of Control Measures for the Toxic Air Contaminant Sulfuryl
Fluoride. Report submitted by the California Department of Pesticide Regulation to the California
Legislature, December 22, 2015.
97 March 14, 2017
residents. Sulfuryl fluoride is not registered for use as a field soil fumigant and is not
used on agricultural fields.
Until 2009, sulfuryl fluoride was believed to have a negligible GWP. Further research
concluded that SO
2
F
2
has a 20-year GWP of 6840, with a lifetime of several decades.
According to the DPR, 3 million pounds of sulfuryl fluoride were used in California in
2013 (most recent data available).
144
Its main use is as a structural pest control
fumigant to kill drywood termites in homes and buildings, accounting for 82 percent of
all usage in 2013. Sulfuryl fluoride is also a common fumigant for dried fruits, nuts, and
other agricultural commodities that must be kept pest-free during storage prior to
shipping (15 percent of all usage in 2013). The remaining three percent of sulfuryl
fluoride application was for other fumigation uses. A complete listing of sulfuryl fluoride
usage in California by commodity is listed in Appendix C.
Because sulfuryl fluoride was not identified as a high-GWP gas by the time AB 32 was
enacted, it was not initially included as a part of ARB's statewide GHG inventory.
However, the annual usage of sulfuryl fluoride is inventoried by DPR as a highly-
regulated pesticide and ARB uses this data to track emissions. In 2013, the 3 million
pounds of SO
2
F
2
usage was equivalent to 9.4 MMTCO
2
E emissions (using 20-year
GWP values), or approximately 20 percent of all F-gas emissions.
Identifying less toxic or lower-GWP alternatives to sulfuryl fluoride remains problematic.
Methyl bromide (CH
3
Br), with a 20-year GWP of 17, was the pesticide fumigant of
choice for many applications until its use was almost completely phased-out by the
Montreal Protocol because of its ozone-depleting potential. Currently, sulfuryl fluoride
is the only fumigant registered for treating structural pests in California. Termites or
other wood-destroying pests are detected in over 250,000 California homes each year,
with the cost of control and repair of damage from dry-wood termites in California
exceeding $300 million annually (with 80 percent of fumigations occurring in Southern
California).
For agricultural commodity fumigation storage (primarily dried fruits and nuts), methyl
bromide is still used on a limited basis through special use exemptions, although its
use is decreasing annually. An alternative fumigant, phosphine (PH
3
), with a GWP
of 0, is also used as an alternative to methyl bromide and sulfuryl fluoride. However,
reported insect tolerance to phosphine has limited its widespread usage.
145
Non-
chemical commodity treatment has been studied since 1995, including irradiation, and
controlling the atmosphere to “suffocate” insects in either low-oxygen or high carbon
144
Summary of Pesticide Use Report Data 2013 - Indexed by Commodity, California. California
Department of Pesticide Regulation, May 2015. Available at:
http://www.cdpr.ca.gov/docs/pur/pur13rep/13_pur.htm.
145
Phosphine Fumigation of Stored Agricultural Commodity - Programmatic Environmental Assessment.
November 2013. United States Agency for International Development (USAID), prepared under
USAID’s Global Environmental Management Support (GEMS) project. Available at:
http://www.usaidgems.org/documents/fumigationpea/fumigationpeafeb24_2014.pdf.
98 March 14, 2017
dioxide environments.
146
Chemical treatment remains dominant due to cost and
feasibility issues of non-chemical alternatives.
The effectiveness of less toxic (and lower-GWP) alternatives to sulfuryl fluoride in
structural fumigation for drywood termites is the subject of much research, opinion, and
disagreement. Structural fumigation generally includes tenting the entire structure and
treating it to kill termites, or more rarely, wood-boring beetles and other pests living in
the structure. While many termite control companies only use sulfuryl fluoride, many
others have begun using alternative termite control methods, including orange oil,
structure heating or extreme cooling, microwaves, and electricity. Additional research
is required before sulfuryl fluoride mitigation measures can be proposed. ARB will
continue working with the DPR to assess mitigation measures to sulfuryl fluoride
emissions. Additional discussion on potential research of sulfuryl fluoride mitigation is
included in Appendix D
146
Alternatives to Methyl Bromide: Research Needs for California - Report of the Methyl Bromide
Research Task Force To The Department of Pesticide Regulation and The California Department of
Food and Agriculture. September, 1995. Available at:
http://www.cdpr.ca.gov/docs/emon/methbrom/mb4chg.htm.
99 March 14, 2017
VII. Achieving Success
Successfully implementing a strategy to reduce SLCP emissions will require integrated
planning to achieve multiple objectives, coordination and collaboration among agencies
at all levels of government, and focused investments and market support.
A. Integrate and Coordinate Planning
The SLCP Reduction Strategy fits within a
wide range of ongoing planning efforts
throughout the State to advance economic
and environmental priorities. Integrated
planning to achieve multiple objectives
requires coordination among planning
agencies and across sectors, systems, and
government jurisdictions. Development of a
strategy to reduce emissions of SLCPs is
being closely coordinated with other
relevant planning efforts. For example, this
SLCP Strategy acknowledges that further
reductions in black carbon from California's
freight system will be realized through
strategies identified in the California
Sustainable Freight Action Plan. That plan
was developed by ARB and other state
agencies, and will accelerate emission
reductions and implementation of zero and
near-zero technology in California’s freight
transport system. Also, ARB staff and local
air districts will develop additional strategies
through the upcoming SIPs process, which
is expected to reduce black carbon
emissions from both mobile and non-mobile
sources.
The 2014 Scoping Plan Update identified
the important role of SLCPs to reduce
climate change impacts and provided
suggested recommended actions for further
emission reductions. Those
recommendations were evaluated and
expanded upon in this SLCP Strategy.
The ARB is embarking on the next update to the Scoping Plan to describe how the
State can meet the State's goal of reducing total GHG emissions by 40 percent by
2030. This SLCP strategy is a forerunner to the Scoping Plan, providing justification
State Plans that will Assist the State
in Meeting SLCP Emission
Reduction Goals
CalRecycle AB 341 Report to the
Legislature
California Sustainable Freight Action Plan
2017 Scoping Plan Update and
Subsequent Updates
2016 California State Implementation Plan
Auction Proceeds Investment Plan
Caltrans Strategic
Management Plan for 2015-2020
Funding Plan for Low Carbon
Transportation Investments and the Air
Quality Improvement Program
Mobile Source Strategy
ARB Annual Research Plan
Climate Change Research Plan for
California
California Water Action Plan
CEC Electric Program Investment Charge
Program
Annual Investment Plan for Alternative and
Renewable Fuels and Vehicle Technology
Program
DWR Climate Action Plan
Bioenergy Action Plan
Healthy Soils Initiative
Forest Carbon Plan
100 March 14, 2017
for accelerated action on SLCP. The next Scoping Plan will augment the strategies
presented in this document with measures focused on CO2, providing a balanced
portfolio of near-term and long-term measures.
Other concurrent planning efforts in the State could also identify additional activities
that may serve to reduce SLCP emissions. For example, CEC's Integrated Energy
Policy Report, the Healthy Soils Initiative, and the Forest Carbon Plan are all ongoing
efforts that intersect with many of the concepts described in this SLCP Report. ARB is
collaborating with other agencies developing those plans to identify and prioritize
activities to reduce SLCP emissions that would also support other State priorities and
integrated planning efforts. Climate action planning efforts by city, county, and other
local government entities will also play a key role in reducing SLCP emissions,
especially if these action plans begin to incorporate SLCP emission inventories and
mitigation actions.
B. Support Local and Regional Leadership
State policy is most effective with the support, engagement, and complementary
actions of regional and local efforts. As the State shifts its climate-protection focus to
the long-term and increases its efforts to reduce SLCP emissions, regional and local
governments and agencies will play an increasingly important role in achieving
California’s GHG goals. The efforts of regional agencies, such as air districts, water
districts, and municipal solid waste authorities, to incorporate GHG emission reduction
strategies into their respective jurisdictions increases the State’s leverage to further
reduce SLCP emissions from various sources.
Local air districts have a key role to play in reducing regional and local sources of
SLCP emissions, because air pollution reduction strategies employed by air districts
often also reduce GHG emissions. For example, the local air districts are participating
in the Interagency Waste Working Group to find regulatory and permitting solutions that
allow for new and expanded organics processing facilities that are protective of public
health as well as reducing GHG emissions due to avoided landfill methane emissions.
City and county governments also play a pivotal role in reducing emissions of SLCPs.
Many GHG emission reduction strategies identified by cities and counties in their local
Sustainability or Climate Action Plans directly correlate to strategies necessary for
SLCP emission reductions, such as improved waste management (increased recycling
and composting), use of alternative and renewable fuels, and simply reducing vehicle
miles traveled. These local government Climate Action Plans encourage, and
sometimes mandate at the local level, actions taken by households and businesses
within a community. Often times, these actions involve behavior change by individuals,
which leads to increased conservation and sustainability, ultimately driving both
community-scale GHG and SLCP emission reductions.
Below are examples of local and regional government efforts that are helping the State
reduce SLCP emissions.
101 March 14, 2017
Methane
In California, agriculture and landfills are the primary sources of methane emissions.
Aside from air district rules to reduce methane emissions at landfills, upstream efforts
by cities, counties, and regional agencies to both reduce and divert food waste and
other organic materials from the waste stream have the potential to greatly reduce
landfill-related methane emissions. Additionally, local municipalities and solid waste
agencies are working collaboratively with air districts to foster renewable fuel
opportunities, such as waste-to-energy and waste-to-fuel projects. For example,
through its leadership role with Clean Cities, the Sacramento Metropolitan Air Quality
Management District is working closely with numerous partners to build awareness and
increase separation and diversion of organic waste to a local anaerobic digester.
Local agencies also play a role in utilizing methane beneficially at wastewater
treatment plants. Many local agencies own and operate wastewater treatment facilities
and are implementing strategies for on-site energy production. Local strategies to
improve management and utilization of organic waste throughout the State may also
have the ability to help reduce methane emissions throughout the agricultural sectors.
Wastewater treatment plants offer a tremendous opportunity to divert organics from
landfills and utilize them for producing energy, transportation fuel, and soil
amendments. Many treatment plants are located near population centers and could
potentially utilize significant amounts of food and other organic waste streams that
come from cities and towns. Collaboration amongst local and regional agencies, such
as solid waste management and wastewater agencies, is the key to success.
Anthropogenic Black Carbon
Local air districts have worked with ARB to
develop programs to comply with federal
air quality standards for PM (that will also
reduce black carbon), such as mandatory
and voluntary rules to restrict residential
wood-burning in fireplaces and wood
stoves, along with incentive programs to
switch to cleaner burning devices.
Districts have also enacted rules regulating
commercial cooking and smoke
management programs addressing
agricultural and rangeland burning
operations, which have reduced black
carbon and PM emissions.
In addition to air district efforts, metropolitan planning organizations, in coordination
with city and county governments, can be credited with efforts to reduce vehicle
emissions, and ultimately on-road related emissions, particularly through their
Sustainable Community Strategy planning and implementation efforts. Local
102 March 14, 2017
governments have stepped up by beginning with their own fleets. For example, in
Sonoma County, the Board directed County staff to reduce emissions from the
County’s on-road fleet by 20 percent by 2010.
Local efforts to reduce diesel particulate matter, such as farm and construction
equipment rules and incentive programs by air districts, play a significant role in the
reduction of black carbon emissions such as the San Joaquin Valley Air Pollution
Control District’s program to replace diesel agricultural irrigation pump engines with
electric motors. In addition, efforts by local port authorities, such as the San Pedro Bay
Standards, have resulted in the establishment of more aggressive targets to reduce
black carbon emissions, health risks, and further improve air quality, particularly for
those in nearby disadvantaged communities.
HFCs and other F-gases
Local air districts can play an instrumental role in aiding the reduction of HFC
emissions, including developing regulations to require low-GWP replacements. For
example, the South Coast Air Quality Management District has three regulations to
reduce refrigerant emissions from stationary air conditioning and refrigeration systems
and motor vehicle servicing, as well as restrictions on CFCs and halons from
sterilization, fumigation, and fire extinguishing equipment. In addition, many local
governments are also tracking emissions of refrigerants, and some have adopted
policies to reduce refrigerant emissions from city-owned air conditioning units, vehicles,
and refrigerators.
C. Investments
Investments in financial incentives and direct funding are critical components for
successful implementation of SLCP emission reduction strategies. Many existing State
funding programs work in tandem to reduce emissions from GHGs (including SLCPs),
criteria pollutants, and toxic air contaminants, and are helping foster the transition to a
clean energy economy. In particular,
State law (Senate Bill 535, De León,
Chapter 830, Statutes of 2012) requires
focused investment in communities
disproportionately impacted by
pollution. Many of these communities,
especially in the Central Valley, along
freight corridors, and in rural parts of
the State, stand to benefit from
dedicated action and investment to
reduce emissions of SLCPs.
Although California has a number of existing incentive programs, the pool of funds is
limited and it is critical to target public investments in ways that encourage system-wide
solutions to produce deep and lasting public benefits. Significant investments of
103 March 14, 2017
private capital, supported by targeted, priority investments of public funding, are
necessary to scale deployment and to maximize benefits. Public investments can help
incentivize early action to accelerate market transition to cleaner technologies, which
can then be supported by regulatory measures. The State must coordinate funding
sources such as the California Climate Investments, supported by the Greenhouse
Gas Reduction Fund (GGRF), Alternative and Renewable Fuel and Vehicle
Technology Program (AB 118), Electric Program Investment Charge (EPIC) Program,
Carl Moyer Program, Air Quality Improvement Program, and Proposition 39 to expand
investments in California’s clean economy and further reductions in SLCPs and other
GHG emissions. Current activities and funding allocations for a few of these programs
are described herein.
The GGRF is an important part of California’s overall climate investment efforts to
advance the goals of AB 32, SB 32, and SB 1383 and target investment in
disadvantaged communities. To guide the investment of Cap-and-Trade auction
proceeds, the Department of Finance, in consultation with the ARB and other State
agencies, is required to submit a triennial Investment Plan to the Legislature. The
Investment Plan identifies priority investments that will help California achieve its GHG
emission reduction goals while realizing additional health, economic, and
environmental benefits. The Investment Plan is required to identify near-term and
long-term GHG emission reduction goals and targets, analyze gaps in current State
funding for meeting these goals, and identify priority investments that facilitate GHG
emission reduction. The second Investment Plan for Fiscal Years 2016-17 through
2018-19 was submitted to the Legislature in January 2016. The Second Investment
Plan identifies potential State investment priorities to help achieve GHG emission
reduction goals, benefit disadvantaged communities, and yield valuable co-benefits
within the Transportation & Sustainable Communities, Clean Energy & Energy
Efficiency, and the Natural Resources and Waste Diversion categories. The priorities
identified in the Second Investment Plan would reduce a range of GHGs, including
short-lived climate pollutant emissions. The Second Investment Plan informed
Governor Brown's 2016-2017 Proposed Budget, which included $215 million of
Cap-and-Trade expenditures specifically targeting SLCP emission reductions. These
expenditures were revised in SB 1613, which appropriates $5 million for black carbon
residential wood smoke reductions, $40 million for waste reduction and management,
$7.5 million for Healthy Soils, and $50 million for methane emission reductions from
dairy and livestock operations.
A critical piece of the State’s investment strategy, which is overseen by ARB and
focused on clean transportation incentives, is the Low Carbon Transportation
Investments and the Air Quality Improvement Program (AQIP). Consistent with the
First Investment Plan, these programs have identified zero-emission passenger
transportation and low-carbon freight transport as investment priorities, which reduce
criteria pollutant and toxic emissions with concurrent reductions in GHG emissions,
including black carbon. ARB has focused AQIP investments on technology advancing
projects that support long-term air quality and climate change goals in addition to
providing immediate emission benefits. In recent years, funding has included rebates
104 March 14, 2017
for zero and near-zero emission passenger vehicles through the Clean Vehicle Rebate
Project (CVRP), vouchers for hybrid and zero-emission trucks and buses through the
Hybrid and Zero-Emission truck and Bus Voucher Incentive Program (HVIP), and the
Truck Loan Assistance Program for small business truck owners in need of truck
replacements or retrofits.
The CEC administers an additional key GHG emission reduction investment program
for the transportation sector—the Alternative and Renewable Fuel and Vehicle
Technology Program (ARFVTP). Funds that are collected from vehicle and vessel
registration fees, vehicle identification plates, and vehicle smog fees provide up to
$100 million per year for projects that will transform California’s fuel and vehicles to
help attain the State’s climate change policies. Investments in alternative fuel
production and infrastructure, and vehicle projects can contribute to SLCP emission
reductions through reduced diesel consumption, capture and use of biogas from waste
management activities as a transportation fuel, demonstration and early
commercialization of advanced technology trucks that utilize biogas, and avoided
fugitive methane emissions from fossil fuel production and distribution operations.
Another CEC-administered program, the Electric Program Investment Charge (EPIC)
Program, supports investments in clean technologies and strategies to improve the
State’s electricity systems. The program provides opportunities to support SLCP
emission reductions from reduced or avoided fugitive methane emissions stemming
from fossil fuel production and distribution via investments such as improved energy
efficiency technologies in building, industrial, agricultural and water sectors; demand
response; distributed renewable generation; electric vehicle infrastructure;
demonstration of biomass-to-energy conversion systems; advanced energy storage
interconnection systems; and vehicle-to-grid power transfer for electric vehicles.
CDFA administers the Dairy Digester Research and Development Program and the
newly created Alternative Manure Management Program that provides grants for
demonstration projects that improve scientific and technical understanding of
technologies and practices that reduce methane and other GHG emissions on dairies.
CalRecycle administers GHG emission reductions grant and loan programs that
include incentives for infrastructure supporting organics diversion. Finally, ARB is
developing an incentive program to replace residential wood burning devices in the
State with cleaner, more efficient devices, thereby reducing GHG, black carbon,
particulate matter and other air toxics emissions.
These programs represent just a portion of opportunities that exist at the federal, State,
and local levels to incentivize SLCP and GHG emission reductions. The availability of
dedicated and long-lasting funding sources is critical to help meet AB 32, SB 32, and
SB 1383 objectives and help provide certainty and additional partnership opportunities
at the national, State, regional, and local levels for further investing in projects that
have the potential to reduce emissions of SLCPs.
105 March 14, 2017
D. Coordinate with Subnational, Federal, and International Partners
California is working with a set of national and subnational partners throughout the
world to fight air pollution and climate change. This includes signatories to the Under 2
MOU, as well as others in Mexico, China, India, the U.S., Canada, and elsewhere.
Many of the efforts underway through these collaborations will help reduce emissions
of black carbon from the transportation sector and emissions of other SLCPs.
At the 2014 United Nations (UN) Climate Summit, ARB became the first state-level
entity to sign onto action statements of the Climate and Clean Air Coalition to Reduce
Short-Lived Climate Pollutants. At the 2014 UN Conference of Parties in Lima,
California co-sponsored an event with Mexico on SLCPs and their role in an
international framework to contribute to national commitments to reduce emissions. At
UN climate meetings in New York and Paris in 2015, Governor Brown presented the
targets described in this SLCP Strategy, and suggested that action on SLCPs may be
the most important and most immediate need to address climate change. The State
continues to be committed to acting both bilaterally and multilaterally to cooperate with
other jurisdictions to cut SLCP emissions, and will explore additional opportunities to
further reduce air pollution, greenhouse gas, and SLCP emissions through
partnerships.
Building on leadership around SLCPs can provide an important example for action in
other countries and jurisdictions, and is one of the most significant opportunities to
accelerate international progress to fight climate change. California is in a unique
position to serve as a model for action for other countries and jurisdictions to
accelerate their progress to reduce emissions of both SLCPs and CO
2
, based on the
State’s demonstrated leadership on air quality and climate change, commitments to set
stringent, science-based targets to reduce emissions of both CO
2
and SLCPs, and
integrated planning efforts, like this one, to develop a comprehensive policy framework
to achieve those goals.
As we have done for decades already, California’s actions on SLCPs can demonstrate
win-win opportunities for both the most developed countries, where reducing SLCP
emissions is an important element of broad efforts to cut GHG emissions, as well as for
the least developed countries, where SLCP emission reductions have tremendous
benefits for air quality and human health.
Ultimately, each state, region, or country has its own mix of SLCP sources, needs, and
opportunities to reduce emissions. Coordinated planning to meet scientific-based
emission targets, like this SLCP Strategy does, is important to successfully reducing
emissions and maximizing local and global benefits.
California will share this planning effort with others, and encourage them to adopt
specific SLCP emission reduction targets and plans to achieve them. A few already
have; the federal government has set specific targets to cut methane emissions from
the oil and gas sector, Mexico has included targets to cut black carbon emissions in its
106 March 14, 2017
Intended Nationally Determined Contribution to the United Nations Framework
Convention on Climate Change, Europe and other countries have taken steps to phase
down the use of HFCs, Australia and Brazil are working to reduce methane from
agriculture, and Norway has developed an SLCP action plan of its own.
147
These
types of commitments and planning efforts need to be adopted more broadly. By
developing a comprehensive plan to achieve necessary SLCP emission reductions in
an effective and beneficial way, California can foster broader action beyond its borders
and demonstrate effective processes and strategies to address climate change.
147
NEA (2014) Summary of Proposed Action Plan for Norwegian Emissions of Short lived Climate
Forcers, Norwegian Environment Agency, March.
http://www.miljodirektoratet.no/en/Publications/2014/March-2014/Summary-of-proposed-action-plan-for-
Norwegian-emissions-of-shortlived-climate-forcers/
107 March 14, 2017
VIII. Evaluations
This chapter discusses the economic, public health, and environmental justice
evaluations of the proposed new measures in this SLCP Strategy. It also discusses
the environmental analysis that was prepared for the SLCP Strategy. It should be
noted that to the extent that any of the proposals in the SLCP Strategy result in
regulatory action, each proposed regulation will be subject to its own public process
with workshops, opportunities for stakeholder discussion, consideration of
environmental justice, and legally required analyses of the economic and
environmental impacts. Staff will track the progress of implementation of the SLCP
measures and provide periodic updates to the Board. This information, as well as
updates to the SLCP emission inventory, will be posted to ARB's SLCP website.
A. Economic Assessment of Measures in the SLCP Strategy
This section presents the economic analyses for the new measures identified in this
SLCP Strategy. Supporting documentation for this analysis is presented in
Appendix F. Activities already underway separately—including development of the
California State Implementation Plan to meet federal health-based air quality
standards, the California Sustainable Freight Action Plan, the 2017 Scoping Plan
Update, and implementation of Senate Bill 1371 (Leno, Chapter 525, Statutes of
2014)—will have important impacts on SLCP emissions in California, but are not
evaluated here.
The analyses presented here consider direct economic costs associated with new
technologies and management strategies that can help to reduce SLCP emissions.
They also consider direct economic benefits in the form of savings as a result of
efficiency improvements or revenue from marketable products. This analysis does not
include a macroeconomic analysis at the statewide level, nor does it include a
monetary accounting of societal benefits, such as the value of reducing exposure to
fine particulate pollution or reducing the impacts of climate change.
While there are potentially significant market opportunities associated with some of the
proposed measures, including putting organics to beneficial use, there are also
substantial costs and funding needs. These include costs to increase market
penetration of existing technologies and research and development of innovative
advanced technology. Initial analyses and various literature sources suggest that
SLCP emissions from several sources, including those identified in this SLCP Strategy,
can be reduced at low, and sometimes negative, lifetime costs.
Long-term regulatory signals can play a vital role in facilitating low cost SLCP emission
reductions. The LCFS and the federal Renewable Fuel Standard (RFS) incentivize the
use of renewable natural gas as a transportation fuel, creating large revenue potential
within the dairy manure and organic diversion measures. These programs in particular
can help support cost-effective projects to reduce methane from the dairy and waste
108 March 14, 2017
sectors. Without the LCFS or RFS programs, additional sources for financial
incentives and funding may be needed.
The measures laid out in this SLCP Strategy are transformative, leading to uncertainty
in the potential costs and revenue of proposed measures as well as the ultimate
pathway to compliance. There is a wide range of potential costs and savings,
uncertainty in how the strategies will be met, and uncertainty in some cases for how
costs in literature translate in the California context. In conjunction with State
agencies, ARB will continue to work closely with stakeholders and manufacturers to
evaluate the feasibility and costs of existing and developing technologies to determine
the best approaches to meeting the targets in the SLCP Strategy.
The measures included in the SLCP Strategy will also strengthen California’s
environment and the economy by developing infrastructure, generating cost savings,
and creating jobs. Measures that reduce methane emissions through waste digestion
will have a large impact on the California economy, including disadvantaged
communities.
The dairy manure measure has the potential to create jobs in California’s Central
Valley. These jobs include construction jobs to build digesters and farm and waste
management jobs to operate and maintain the facilities. In this analysis, it is assumed
that the construction of an anaerobic digester for a 2,000 head dairy farm can result in
25 to 60 construction jobs and 2 to 5 full-time farm jobs.
148
If digesters were built on
farms accounting for about 1 million dairy cows, many in the San Joaquin Valley, it
could result in over 30,000 construction jobs and 2,500 permanent jobs potentially
providing employment opportunities in disadvantaged communities.
Diverting organic waste can also result in increased employment, providing an
estimated additional 2 jobs per 1,000 tons of diverted organic material.
149
In 2025, this
could result in 25,000 additional jobs in waste management and garbage collecting,
food recovery and distribution. As demonstrated in the CalRecycle funded Food to
Share project, food waste prevention programs not only produce emission reductions,
but employment and nutritious meals to California’s most vulnerable populations.
150
The proposed measures will also build on and support existing California efforts related
to climate change and air quality. Measures will support infrastructure, research,
development, and deployment of advanced technologies that will help achieve
California’s near- and long-term climate and air quality goals. Encouraging the
collection of methane gas from waste streams, for example, can provide renewable
fuel to reduce the carbon footprint of the transportation sector. Associated efforts
148
Sample of industry information relied upon for the estimate:
http://www.gundersenenvision.org/renewable-energy/turning-cow-waste-into-energy-middleton and
http://www.usda.gov/oce/reports/energy/Biogas_Opportunities_Roadmap_8-1-14.pdf.
149
http://www.calrecycle.ca.gov/publications/Documents/1463%5C20131463.pdf
150
More information available at: http://greenlining.org/wp-
content/uploads/2015/10/CAClimateInvestmentsCaseStudies.pdf.
109 March 14, 2017
related to the 2017 Scoping Plan Update, the California State Implementation Plan,
and California’s Sustainable Freight Action Plan stand to benefit from activities to cut
SLCP emissions
The 2017 Scoping Plan Update, expected to be finalized in 2017, will include a detailed
macroeconomic assessment of California’s complete climate change mitigation
strategy, including those contained in the final SLCP Strategy. While this SLCP
Strategy begins to explore the costs and benefits of proposed measures, the 2017
Scoping Plan Update will contain a detailed economic analysis including a
comprehensive assessment of the impact of California’s climate strategy on
Californians, businesses, Disadvantaged Communities, and the California economy.
All proposed SLCP strategies that are implemented as regulations will also be subject
to the economic requirements of the Administrative Procedures Act (APA) as part of
the public regulatory process. Prior to finalization, regulatory measures will be
analyzed in a public process including an Economic Impact Statement, Economic
Impact Assessment, and a Standardized Regulatory Impact Assessment for major
regulations. Therefore, there will be many opportunities for stakeholders to assess the
economic impact of measures in the SLCP Strategy as they are being developed.
The costs, savings, and potential revenue streams of the five measures are assessed
in the following sections, 1 through 5. Collectively, implementing these measures
would require several billion dollars of investment in clean technologies and strategies
that would lead to significant reductions in SLCP emissions. Potential revenues and
efficiency gains could also be significant—potentially outweighing the costs of some
measures. In other cases, there may be net costs, but associated SLCP emission
reductions may come at relatively low cost or provide other environmental and health
benefits. While uncertainties remain—especially for costs and revenues associated
with some strategies that utilize either emerging technologies or those that have not
been widely deployed already in California—these measures can help to significantly
cut SLCP emissions in California at reasonable cost. With ongoing, targeted financial
and market support, coordinated with regulatory development and other economic and
environmental priorities where appropriate, California can meet the targets identified in
this SLCP Strategy while delivering a broad range of benefits.
1. Residential Wood Combustion Black Carbon Emission Reductions
Residential wood combustion (RWC) constitutes 15 percent of California’s
anthropogenic black carbon (BC) emissions, and is projected to be the largest
individual source of BC by 2030. This Strategy recommends a 3.0 MMTCO2e (20-yr
GWP) reduction in RWC BC emissions by 2030 to meet the SLCP BC emission
reduction target.
There are a variety of ways to reduce RWC emissions, and multiple air districts have
already put measures in place. Past incentive programs to replace old polluting wood-
burning devices with the cleanest EPA-certified devices have been popular. However,
110 March 14, 2017
rural districts that rely most heavily on RWC for their primary source of heat are largely
located outside of regions that provide incentives. Additionally, past incentive
programs have not acquired sufficient funding to achieve the substantial emission
reductions proposed in this strategy.
The cost share of this strategy between homeowners and governmental incentives
primarily depends on the incentive amount provided per device, and total costs depend
on the emission reductions achieved per device. Both of these factors will vary by
region and by household, thus incentives funding and homeowners’ share of costs are
calculated as a range. The cost to replace a device with a certified wood burning or
gas device can range between $3,000 and $5,000, while some options, such as full
HVAC installation can cost up to $10,000.
151
Purchase and installation of woodstoves
was assumed to cost $4,000 while gas or small electric devices were assumed to cost
$4,500. Incentives typically cover a portion of the cost, from $1,000
152
up to the full
installation price.
153
Many rural areas that rely heavily on wood combustion as a
source of heat will require nearly full coverage of the installation price to spur voluntary
participation. The range of incentives was assumed to be $1,000 to $4,500 to cover
various cases.
The BC emission reduction per household depends on how much wood is burnt per
year, the density and moisture content of the wood, the old device type, and the new
device type. Emissions were calculated for two replacement cases. The “wood to
wood” case assumes conversion of non-certified woodstove to EPA-certified wood
stove.
154
This case assumes that new EPA-certified devices work as certified, but
real-world use may lead to higher than certified emissions if proper burn practices are
not followed. If emissions do not meet certified levels, the level of health benefits and
cost effectiveness of incentive dollars may not be realized. Emission reductions are
more certain in the “wood to gas or electric” case where a non-certified woodstove is
replaced by a gas or electric heating device. Conversion to natural gas or electric
heating devices assumes 100 percent reduction in local PM emissions.
Actual incentive programs will likely contain a mixture of different replacement types
and these two cases are used to bound potential emission reductions and costs. Other
parameters used in emission reduction calculations were provided by the U.S. EPA
residential wood combustion replacement calculator, which includes California-specific
data when available (Table 12).
155
The calculator was updated to account for
151
USEPA (2014). How to Implement a Wood-Burning Appliance Change out Program. Available at:
http://www.epa.gov/sites/production/files/2015-08/documents/howtoimplementawoodstovechangeout.pdf
152
SJVAPCD (2016). Burn Cleaner Program. http://valleyair.org/grants/burncleaner.htm
153
http://www.epa.gov/sites/production/files/201508/documents/howtoimplementawoodstovechangeout.p
df
154
Specifically, a woodstove that meets the U.S. EPA 2020 new source performance standard (2.0
grams particulate matter per hour) USEPA (2015). Fact Sheet: Summary of Requirements for
Woodstoves and Pellet Stoves. Available at: http://www.epa.gov/residential-wood-heaters/fact-sheet-
summary-requirements-woodstoves-and-pellet-stoves
155
USEPA (2009). Burn Wise Additional Resources - Emission Calculator.
http://www.epa.gov/burnwise/burn-wise-additional-resources
111 March 14, 2017
replacement with cleaner EPA-certified wood burning devices that will be required by
2020.
Table 12: Emission Summary
Parameter
Wood to
Wood
Wood to Gas
or Electric
Cords wood burnt per year
156
1.5
1.5
Wood Density (tons/cord)
157
1.04
1.04
PM
2.5
Emission Reductions per device
(tons/yr)
158
0.0218
0.0245
BC Speciation (fraction of PM
2.5
)
159
0.125
0.125
BC Reduction per device per year
(MTCO2e, 20-yr GWP)
7.9
8.9
BC Emissions Target 2030
(MTCO2e, 20-yr GWP)
3,000,000
3,000,000
Number of average replacements needed to
meet target
379,000
337,000
The cost of incentives was calculated by multiplying the number of replacements
needed to meet the target (Table 12) by the range of incentives that could be provided,
from $1,000 to the full cost of replacement.
160
The cost to homeowners was calculated
as the total replacement cost, minus the portion covered by incentives. The “low
incentives” case in Table 13 is a scenario where only $1,000 in incentives is paid, and
homeowners pay a portion of the replacement. In the “high incentives” case,
incentives cover 100 percent of replacement costs and homeowners pay no money out
of pocket. Costs to oversee and administer the incentives program were assumed to
be similar in either case, because a similar number of devices are replaced (Table 12),
and were calculated as 10 percent of the lower incentive value.
161
Educational and
outreach costs were estimated at one percent of the lower incentives value. Education
and outreach includes education about the health effects of wood smoke and
educating residents about proper use of their new devices to minimize emissions and
maximize the lifetime of the equipment. Studies indicate that education and outreach
are vital components of RWC replacement programs.
162
A summary of costs can be
found in Table 13. The results show that the total costs for either a low incentives or
high incentives case would be the same, but the distribution of costs between
incentives and homeowner responsibility is different. These scenarios represent
156
Based on average California Climate, from USEPA Emission Calculator.
157
Average California wood density, from USEPA Emission Calculator.
158
Results are from USEPA Emission Calculator for wood to gas conversion. This result assumes
approximately 100% reduction in PM.
159
ARB (2015). 2015 Edition Black Carbon Technical Support Document. Available at:
http://www.arb.ca.gov/cc/inventory/slcp/slcp.htm
160
$4,000 for woodstove installation and $4,500 for gas devices.
161
http://www.epa.gov/sites/production/files/201508/documents/howtoimplementawoodstovechangeout.p
df
162
http://www.epa.gov/sites/production/files/201508/documents/howtoimplementawoodstovechangeout.p
df
112 March 14, 2017
extremes use to bound the range of possible costs; actual program implementation
may lie between the low and high incentives cases presented in Table 13.
Table 13: Range of Costs (Million Dollars)
163
Cost
Low Incentives
High Incentives
Incentives
$340
$1,500
Oversight and Administration
$34
$34
Cost to Homeowners
$1,180
$0
Education and Outreach
$3.4
$3.4
Total Cost
$1,557
$1,537
Savings associated with this strategy include reduced wood use in more efficient
devices or any savings (or cost) to convert from wood fuel to natural gas. U.S. EPA
estimates that EPA-certified devices burn a third less wood for the same heat output.
164
Table 14 summarizes the range of potential savings depending on the conversion
scenario.
Wood to wood total savings were calculated using the average annual amount of wood
burnt (Table 12), the fraction of residents who pay for wood,
165
the cost of a cord of
wood, and the assumption that a third less wood is used by the replaced devices.
However, if new devices do not prove to be as efficient as U.S. EPA certification
standards indicate, then full savings may not be realized. This analysis assumes
20 percent of wood is gathered for free, and would not provide a savings to the
resident. The cost of a cord of wood will vary from approximately $100 to $480
depending on location and type of wood.
166
This analysis uses the midpoint value of
$290 per cord. Reducing annual wood consumption from 1.5 to 1 cord per year would
save the average resident $145 per year. Approximately 379,000 wood to wood
conversions (Table 12) would result in savings of approximately 44 million dollars per
year to consumers receiving incentives to replace their inefficient wood stove.
Wood to gas or wood to electric savings can be calculated assuming 1.5 cords of wood
are not purchased (Table 12), the cost of wood is $290 a cord, and that the heat-
equivalent amount of natural gas or electricity must be purchased, and assuming
337,000 devices are replaced (Table 12). The price of natural gas was assumed to be
$11.51 per thousand standard cubic feet.
167
The price of electricity was assumed to be
163
Low incentives are $1,000 and high incentives cover 100 percent of device purchase and installation
costs ($4,000-$4,500 depending on the device). Under the high incentive there is no out of pocket
expense to homeowners.
164
http://www.epa.gov/sites/production/files/201508/documents/howtoimplementawoodstovechangeout.p
df
165
A portion of residents who rely on residential wood combustion for heat gather wood from local lands
at no cost.
166
CDFA (2010). California Department of Food and Agriculture News Release. Available at
https://www.cdfa.ca.gov/egov/Press_Releases/Press_Release.asp?PRnum=10-074
167
EIA (2015). California 2014 price of natural gas delivered to residential customers. Available at
https://www.eia.gov/dnav/ng/ng_pri_sum_dcu_SCA_a.htm.
113 March 14, 2017
16.3 cents per kWh.
168
The savings from not purchasing wood is nearly in balance
with the additional cost of purchasing natural gas using these assumptions, while
electricity is estimated to cost about four times more than wood (Table 14). Thus,
electricity purchase would likely represent an additional cost to homeowners.
Table 14: Savings Associated with Residential Wood Stove Conversion
(Million Dollars)
Conversion Scenario
Savings on
Purchase of Wood
Increased Cost
for Natural Gas
or Electricity
Net Fuel
Savings
100 % Wood to Wood
$44
$0
$44
100 % Wood to Gas
$117
$109
$8
100 % Wood to Electricity
$117
$464
-$347
2. Methane Emission Reductions from Dairy Manure
The economic analysis investigated a reduction in dairy manure emissions that could
come from a mix of voluntary and regulatory efforts to reduce emissions from the
equivalent of about 1 million cows, equivalent to an annual methane reduction of
22 MMTCO
2
e by 2030, and a cumulative reduction of 166 MMTCO
2
e through 2030
using the assumptions in this analysis (7.8 MMTCO
2
e and 57.6 MMTCO
2
, respectively,
using a 100-year GWP). This analysis will be further refined in coordination with
stakeholders as measures are developed.
The analysis included six potential pathways for dairies to mitigate manure methane.
These represent example pathways that could be important to a sector-wide approach
to reduce emissions, but they are not meant to rule out other solutions. Not every
pathway may be feasible for every dairy, and a variety of pathways will be employed to
reach the targets.
This analysis relies on a number of assumptions that may not fully account for all
barriers a project could face, such as up-front financing challenges or permitting
issues. On the other hand, cost estimates are based on current and past projects, and
may over-represent future costs that could come down from economies of scale or
technology improvements. Still, this analysis shows the potential for strategies to
improve management of dairy manure and produce revenue-positive, value-added
products, such as transportation fuels, while providing GHG, and potentially also
criteria pollutant, benefits.
The six major pathways analyzed were:
1) Scrape conversion and onsite manure digestion producing:
168
EIA (2015). Annual Average Retail Price of Electricity to Ultimate Customers by State and Utility.
Table 6 - 2014 Utility Bundled Retail Sales – Residential filtered for California. Available at:
http://www.eia.gov/electricity/data.cfm#sales
114 March 14, 2017
a) electricity or
b) pipeline-injected renewable natural gas vehicle fuel
2) Scrape conversion and transport of manure offsite for centralized digestion (cluster)
producing:
a) electricity or
b) pipeline injected renewable natural gas as a vehicle fuel
3) Retain existing manure lagoon management with onsite covered lagoon digestion
producing:
a) electricity or
b) pipeline-injected renewable natural gas vehicle fuel
4) Retain existing manure lagoon management with onsite covered lagoon digestion,
and convey biogas to a central location (cluster) via low-pressure collector pipeline
for biogas clean-up to produce:
a) electricity or
b) pipeline-injected renewable natural gas vehicle fuel
5) Conversion of dairy operations to pasture-based management
6) Scrape conversion, collection and open solar drying of manure onsite
The first pathway assumes conversion to solid manure management (scrape), and
development on digesters onsite at each dairy to produce either electricity using micro
turbines or transportation fuel. The second pathway is the same as the first, but
captures economies of scale by utilizing centralized digesters for a “cluster” of dairies.
In the second pathway, manure is assumed to be trucked to the central digestion point.
Pathway 2 only includes a subset of California’s dairies that were within reasonable
clustering distance using a GIS analysis (within 5 miles on average). The third
pathway retains the existing lagoon manure management, utilizes a covered lagoon
digester, with the resulting biomethane producing either electricity or transportation
fuels. Pathway 3 only includes the subset of dairies practicing flush management. The
fourth pathway is similar to pathway 3—dairies maintain existing lagoons, continue to
use flush management, but capture economies of scale by delivering biogas via
pipeline to a central location for upgrading and interconnection. Pathway 4 uses the
same dairy clusters identified in Pathway 2, but does not assume dairies convert to
scrape, and convey gas by low-pressure pipeline to the central location rather than
trucking manure. In the fifth strategy, dairies convert to pasture-based operations; no
revenue is assumed from this pathway. Finally, the sixth pathway mitigates manure
methane emissions by converting from flush management to scrape systems, but is
assumed to generate no revenue. There could also be potential revenue (along with
added costs) if manure were composted and sold, which is not considered here. This
represents a relatively low cost option compared to the other pathways, but low value
as well. The cost and efficacy of some mitigation options, such as solids separation,
were not yet known with certainty and could not be included in this analysis. Solids
separation and other potential mitigation methods deserve additional study of both
emission reduction potential and economic feasibility.
115 March 14, 2017
Cost Analysis Methodology
Cost analyses were based on a Geographic Information System (GIS) analysis of
dairies throughout the State. The GIS analysis used information about the size,
associated crop land, and location of dairies to inform feasibility of pipeline injection,
pasture-based management, and dairy-specific costs for each pathway listed above.
Analyses were also performed to understand the feasibility and cost savings
associated with “clustering” dairies to centralize digestion by defining 55 potential
central cluster locations and identifying dairies to feed into each cluster. The dairy-
specific economics were calculated for each pathway to account for cost differences in
dairy herd size and distance from transmission pipelines or central digestion locations.
Figure 10 provides a spatial analysis of manure from milking cows in California.
116 March 14, 2017
Figure 10: Location of Manure from Milking Cows in California
The economic analysis was informed with consultation from CDFA, academic
researchers at UC Davis and elsewhere, project developers, and stakeholders. In
particular, as part of developing this SLCP Strategy, ARB supported research at UC
Davis to inform cost and performance estimates for dry scrape conversions, anaerobic
digesters, and other pathways.
169
Additional research was also used to inform the cost
169
Kaffka, S. et al (2016) Evaluation of Dairy Manure Management Practices for Greenhouse Gas
Emissions Mitigation in California, Final Technical Report to the State of California Air Resources Board,
February 2016. http://biomass.ucdavis.edu/wp-content/uploads/2016/06/ARB-Report-Final-Draft-
Transmittal-Feb-26-2016.pdf
117 March 14, 2017
and performance parameters assumed for this analysis, which are detailed in
Appendix F.
170
Pathways that inject biomethane into the pipeline for use as transportation fuel are
assumed to receive revenue for energy sales at the price of wholesale natural gas
($3.46/Mscf), as well as LCFS credits ($100/MT) and cellulosic RIN credits
($1.85/RIN)
171
from the federal Renewable Fuel Standard program. Dairies that
receive LCFS credits cannot also receive Cap-and-Trade credits for the same volume
of biomethane.
172
Pre-regulation and post-regulation LCFS carbon intensities and
associated revenue were calculated using the same assumptions as the 2015 LCFS-
certified California bioenergy Dairy Biogas prospective pathway.
173
Pathways that
produce electricity assume the use of microturbines to limit NOx emissions and receive
revenue from SB 1122 electricity sales subsidies ($0.126/kWh) and Cap-and-Trade
offsets ($13/MTCO
2
e). No revenue was included for soil amendment products that
could potentially provide value,
174
because their market remains uncertain. Each
pathway was analyzed using LCFS or carbon credits both pre and post regulation.
Biogas production for above ground or plug-flow digesters are assumed to use
100 percent of manure volatile solids from milking cows, while covered lagoon
digesters are assumed to capture 60 percent of manure volatile solids due to losses
during solids separation. In addition, above ground or plug-flow digesters are
estimated to be 11 percent more efficient per pound of manure.
175
In balance, biogas
production per cow is approximately two times larger for above ground or plug-flow
digesters as covered lagoon digesters using these assumptions, though real-world
technology implementation may differ from these assumptions. The baseline methane
mitigated (destroyed) is similar regardless of technology so LCFS revenues are similar
for covered lagoon and above ground tank or plug-flow digesters, while revenue from
RIN credits varies in proportion to biogas production.
Example Economic Analysis for a 2,000 Milking Cow Dairy
A full economic analysis was performed for each pathway on a dairy-by-dairy basis to
account for cost differences between dairies of different sizes. However, to provide an
overview comparison by pathway, the costs and revenues for an example 2,000 cow
170
In particular: Sustainable Conservation (2015) Combating Climate Change: Dairies Key in Reducing
Methane, July: http://www.suscon.org/blog/2015/07/combating-climate-change-dairies-key-in-reducing-
methane/.
171
The assumed cellulosic RIN credit value of $1.85 includes a D5 RIN ($0.85), cellulosic waiver credit
($0.90) and value from the Blenders Tax Credit ($0.10 per D5 RIN).
172
ARB (2016). Staff Summary, Method 2B Application: Prospective Pathway Dairy Biogas to CNG.
www.arb.ca.gov/fuels/lcfs/2a2b/apps/Calbio-122115.pdf
173
Id
174
Soil amendment products from dairy digesters could provide as much as $300 per cow per year in
California. Informa Economics (2013) National Market Value of Anaerobic Digester Products.
175
Kaffka, S. et al (2016) Evaluation of Dairy Manure Management Practices for Greenhouse Gas
Emissions Mitigation in California, Final Technical Report to the State of California Air Resources Board,
February 2016. http://biomass.ucdavis.edu/wp-content/uploads/2016/06/ARB-Report-Final-Draft-
Transmittal-Feb-26-2016.pdf
118 March 14, 2017
flush dairy are summarized in Table 15. The table includes the net present value for
each pathway over a 10-year time horizon, assuming a 10 year loan on capital at
7 percent interest, and a 5 percent discount rate. Results are presented both
pre-regulation, and post-regulation to examine the effects of regulation on LCFS credit
generation and net present value of the project. Regulation would increase the carbon
intensity of projects producing transportation fuels, reducing the revenue from LCFS
credits, and would eliminate issuance of carbon offset credits for new projects that
generate electricity and are built after the regulation is in place as these projects would
not be additional as required by AB 32. However, the value of these revenue streams
could also be higher than assumed in this analysis, which would increase revenues
and net present values beyond those listed in the table. The detailed calculation
methodology, assumptions, and references for Table 15 are included in Appendix F.
119 March 14, 2017
Table 15: Economic Analysis for Projects at an Example Flush Dairy with 2,000 Milking Cows Over a 10-year
Period, considering value pre and post regulation.
176
(All costs and revenue in million dollars)
Pathway
1a
1b
2a
2b
3a
3b
4a
4b
5
6
Scrape,
Onsite
Digestion to
Electricity
Scrape,
Onsite
Digestion to
Fuel
Scrape,
Central
Digestion to
Electricity
Scrape,
Central
Digestion to
Fuel
Lagoon,
Onsite
Digestion to
Electricity
Lagoon,
Onsite
Digestion to
Fuel
Lagoon,
Onsite
Digestion to
Electricity with
Centralized
Clean-up
Lagoon,
Onsite
Digestion to
Fuel with
Centralized
Clean-up
Pasture
Scrape
Only
Capital
$6.9
$7.2
$6.8
$5.3
$5.1
$7.2
$5.7
$5.9
$7.2
$1.6
O&M
$5.5
$5.3
$4.8
$4.5
$3.1
$4.2
$2.5
$4.3
$2.8
$0.4
Carbon Credits
$1.5
--
$1.5
--
$1.5
--
$1.5
--
--
--
LCFS pre-reg
--
$6.7
--
$6.7
--
$6.4
--
$6.4
--
--
LCFS post-reg
--
$0.8
--
$0.8
--
$0.5
--
$0.5
--
--
RINS
--
$8.2
--
$8.2
--
$4.4
--
$4.4
--
--
Other Revenue
$2.1
$1.1
$2.1
$1.1
$1.1
$0.6
$1.1
$0.6
--
--
Revenue pre-regulation
177
$3.6
$16.0
$3.6
$16.0
$2.6
$11.4
$2.6
$11.4
--
--
Revenue post-
regulation
178
$2.1
$10.2
$2.1
$10.2
$1.1
$5.4
$1.1
$5.4
--
--
10-year net present value (NPV) and cost effectiveness pre-regulation
NPV (million $)
–$8.8
$3.6
–$8.0
$6.2
–$5.6
$0
–$5.7
$1.2
–$9.9
–$2.1
$/MT CO
2
e (20-yr GWP)
21
–8
19
–15
13
0
13
–3
29
5
$/MT CO
2
e (100-yr GWP)
60
–24
55
–42
38
0
39
–8
82
14
10-year net present value (NPV) and cost effectiveness post-regulation
NPV (million $)
–$10.3
–$2.3
–$9.5
$0.4
–$7.1
–$6.0
–$7.2
–$4.8
–$9.9
–$2.1
$/MT CO
2
e (20-yr GWP)
24
5
23
–1
17
14
17
11
29
5
$/MT CO
2
e (100-yr GWP)
70
15
65
–3
48
41
49
33
82
14
176
Summation may not be exact due to rounding. Capital costs amortized over 10 years with 7% interest. Discount rate is 5%. Costs normalized
to example 2,000 cow dairy.
177
Pre-regulation revenue includes carbon credits, pre regulation LCFS value, RINS, and other revenue.
178
Post-regulation revenue includes post-regulation LCFS value, RINS, and other revenue; carbon credits have zero value in the post-regulation
scenario.
120 March 14, 2017
Table 15 shows the potential for large revenue from both LCFS and RIN credits for
transportation fuels production. With this revenue in place multiple pathways are
revenue positive or revenue neutral over 10 years. However, credit prices under these
programs can be volatile, and securing funding for projects with uncertain revenue
sources is challenging. Even with LCFS and RIN credits, these projects may need
financing assistance, either in the form of up-front grants, or other mechanisms that
can help to secure project financing, such as the pilot financial mechanism for diaries
required by SB 1383. Regulation reduces the value of LCFS credits and eliminates
carbon credits for new dairy projects. Table 15 shows that, with regulation in place, the
revenue from LCFS credits for new projects declines significantly. California regulation
would not affect RIN values, so the post-regulation net present value includes full RIN
revenue. In the absence of both RIN and LCFS revenue no dairy project would be
revenue positive over 10 years.
Cost Curves for California’s Dairies
Data in Table 16 represent a 2,000 milking cow dairy to compare the relative costs and
revenue by pathway for a dairy, however, costs will not be consistent across dairy
sizes or location. A dairy-by-dairy economic analysis was performed to better account
for this. Capital, annual operations and maintenance, and annual revenue were
calculated for each dairy in California to provide cost curves by pathway (Figure 11).
To illustrate costs and cost-effectiveness, cost curves are presented both with and
without revenue in Figure 11.
121 March 14, 2017
Figure 11: Individual Dairy Cost Curves by Pathway
Based on the assumptions used here, projects at dairies show the potential to reduce
manure methane emissions, at fairly low or negative costs compared to other sources.
However, dairies are unique because milk prices are fixed, thus dairy operations
cannot pass on increased production costs. Many dairies in California are currently
operating at a loss, so even comparably low-cost emission reduction options such as
these could pose a financial burden to the dairy industry.
Projects that generate transportation fuel and capture RIN and LCFS credits (1b, 2b,
3b, and 4b) have the potential to generate significantly more revenue than other
pathways, and have the potential to be revenue positive over 10 years for many dairies
in California (Figure 11). All other pathways that do not generate transportation fuels
are revenue negative over 10 years for any dairy in California, using the assumptions
here, and would need additional financial assistance to be economically viable over
that time frame. Additionally, no modeled project is revenue positive in the absence of
LCFS and RIN credits.
Costs and Revenues for Sector-Wide Scenarios
The sector-wide total implementation cost to achieve a 22 MMTCO
2
e dairy manure
methane reduction depends on the pathway utilized by each dairy, which is difficult to
predict. To bound potential costs, this analysis assumes that dairies would choose the
pathway with the highest net present value if LCFS and RIN credits were available
122 March 14, 2017
(2b – scrape conversion with central digestion to fuel), or that dairies would choose the
lowest cost option in the absence of revenue (6 – scrape conversion only). This
provides a likely cost bounding considering scenarios with and without LCFS and RIN
credits. It is important to note that these scenarios were selected as an economic
bounding exercise, and they are not intended to suggest a preferred or expected path
forward. For example, there are still outstanding questions about the costs and
feasibility of converting California’s dairies from lagoon flush management to scrape,
which should be investigated going forward. Actual implementation of any regulatory
requirements will likely include a suite of potential mitigation options, which will allow
each dairy operation to select their preferred mitigation option.
Sector-wide costs, revenue, and cumulative methane mitigation were calculated
through 2030, though additional costs and benefits would accrue after this date.
Pathway 6 contains no revenue, while pathway 2b receives revenue from RIN and
LCFS credits as well as sale of biogas. RIN credits were assumed to be available for
all years through 2030. LCFS credits were calculated for three scenarios to account
for the effect of regulation on revenue: no regulation, regulation in 2026, and regulation
in 2024. Regulation effective dates were assumed to be January 1st of the regulation
year. Any project started before the effective date of the regulation receives LCFS
credits for methane destruction for 10 years. After 10 years, it is assumed that the
dairy no longer receives credit for methane destruction which increases the carbon
intensity score under the LCFS and significantly reduces LCFS revenue for any
remaining year through 2030. Some dairies could potentially reapply for methane
destruction credits for an additional 10 years but this option was excluded in this
analysis for simplicity. Projects started after the regulation date do not receive credit
for methane destruction and receive the higher carbon intensity score for LCFS credits
through 2030. In the no regulation case, all projects receive the full LCFS credits for
up to10 years and the higher CI LCFS credits for any remaining years through 2030.
The detailed calculation methodology, assumptions, and references for Table 16 are
included in Appendix F.
123 March 14, 2017
Table 16: Sector-wide costs for two bounding scenarios through 2030
179
Pathway
2b Scrape, Central Digestion to Fuel
6
No Regulation
2026
Regulation
2024
Regulation
Scrape
Only
Capital (billion $)
$1.5
$1.5
$1.5
$0.5
O&M (billion $)
$1.3
$1.3
$1.3
$0.1
Revenue (billion $)
LCFS ($100)
$2.1
$1.9
$1.6
--
RINs ($1.85)
$2.7
$2.7
$2.7
--
Other*
$0.4
$0.4
$0.4
--
NPV (billion $)
$2.4
$2.2
$2.0
–$0.7
$/MT CO
2
e (20-yr GWP)
–15
–12
–13
4
$/MT CO
2
e (100-yr GWP)
–43
–39
–34
11
*Sale of biogas at $3.46 per 1,000 SCF.
This analysis suggests that the dairy industry in California can cut methane emissions
and deliver low-cost GHG reductions. Pathway 6, scrape conversion only, is a
relatively low cost option compared to other pathways, but also assumed to be low
value. Pathway 2b, cluster and fuel production, represents a potentially high value
scenario, but would require significantly more technology and investment (including
upfront capital), and relies on volatile revenue sources.
Regulation has a significant effect on potential LCFS credits in pathway 2b. The
sector-wide effect of regulation on LCFS revenue depends on the timeline that dairy
projects come online. Regulating in 2024 versus 2026 reduces cumulative LCFS
revenue to the industry by about $300 million, although the sector-wide net present
value (NPV) with a 2024 regulation is estimated to be positive, at $2.0 billion through
2030. This positive sector-wide NPV does not mean all dairies are profitable. As
exemplified in Table 16, regulation significantly reduces the LCFS revenue a dairy
receives. In the 2024 regulation scenario, all dairies that come online before the
regulation are profitable without additional financial assistance, while some dairies that
come online after the regulation would lose money over a 10 year loan period using
these assumptions and without additional financial support. It could make sense, then,
for more dairies to pursue earlier project development, which could increase revenues,
cost effectiveness, and emission reductions beyond those simulated here.
Table 17 presents the sector-wide cumulative upfront capital costs and implementation
assumptions for the two sector-wide scenarios. Upfront capital costs are a measure of
investment needed to get projects off the ground and do not include annual operational
costs or revenue. As noted previously, actual implementation will utilize a range of
mitigation options and these two scenarios provide a possible bounding of upfront
costs. Cumulative capital investment of between $600 million and $1.7 billion would be
179
Summation may not be exact due to rounding. Capital costs amortized over 10 years with 7%
interest. Discount rate is 5%. All costs and revenues are calculated through 2030, though additional
costs and benefits will accrue after 2030.
124 March 14, 2017
needed by 2030 to meet the 22 MMTCO
2
e reductions using assumptions in this
analysis. In the near term, $200 million to $500 million would be necessary to reduce
dairy manure methane by 20 percent in 2020.
Table 17: Sector-wide implementation assumptions, and upfront capital costs
180
Pathway 2b
Pathway 6
Scrape, central digestion, fuel
Scrape only
Year
Cumulative
Upfront Capital
(Billion $)
Number of
Clusters
Number of
Dairies
Cumulative
Upfront Capital
(Billion $)
Number of
Dairies
2020
$0.5
11
95
$0.2
56
2025
$1.2
32
294
$0.4
213
2030
$1.7
55
543
$0.6
493
Funding support, loan guarantees, or incentives will likely be necessary to achieve
rapid manure methane mitigation targets under any scenario. Several existing and
potential funding sources are available, including those from federal sources,
California’s Greenhouse Gas Reduction Fund (GGRF), utility programs, private
investors, the programs included in this analysis, or other sources. Limited federal
grant funding is currently available, and more should be pursued. The legislature
appropriated $50 million in GGRF funding for fiscal year 2016-2017 to achieve early
and extra methane emission reductions from dairy and livestock operations, and an
additional $7.5 million to support the Healthy Soils Program, including compost
applications.
181
Additionally, AB 2313 provides utility incentives of up to $3 million to
offset utility interconnection costs associated with biomethane projects, and up to $5
million for dairy cluster projects, including the costs of gathering pipelines. It directs the
PUC to keep this program in place through December 31, 2021. Senate Bill 1383
directs state agencies to consider or develop additional policies to support dairy
biomethane and other renewable gas projects including: energy infrastructure and
procurement policies, financial mechanisms to reduce the uncertainty of value under
the LCFS, rate-basing pipeline infrastructure for no fewer than five dairy biomethane
pilot projects, and other policies and incentives to significantly increase the sustainable
production and use of renewable gas in the state. Altogether, these policies provide a
strong starting point for developing projects to reduce dairy manure emissions in
California.
This analysis provides the initial framework for understanding costs and potential
revenue associated with manure methane reductions in California. As mentioned
previously, this analysis is purely economic and there are important uncertainties
associated with project costs and potential revenues, as well as barriers to
implementation that may limit project development without targeted support. State and
local governments may wish to support some higher cost strategies for other
environmental or health reasons. This document represents a starting point for
discussion that should be built upon and bolstered. The working group referenced in
180
Capital costs are discounted at 5%, does not include operating costs or revenue. Cumulative upfront
capital represents anticipated financing needs.
181
Assembly Bill 1613 (Chapter 370, Statutes of 2016)
125 March 14, 2017
Chapter V may be helpful in recommending ways to leverage private sector investment
and scale efforts to rapidly cut methane emissions in California.
3. Methane Emission Reductions from Diversion of Landfill Organic Waste
As noted in Chapter V, meeting the SB 1383 organic diversion targets can reduce
landfill emissions by 4 MMTCO
2
e in 2030, but one year of waste diversion in 2030 is
expected to avoid 14 MMTCO2e of emissions over the lifetime of waste decomposition.
Achieving these methane emission reduction targets requires developing infrastructure
and markets to optimize the economic and environmental value of California’s waste
streams across sources.
When considering waste diversion options it is essential to balance environmental and
economic benefits with any potential impacts on criteria pollutant emissions and
ecosystem and human health, especially in disadvantaged communities. Avoiding
organic waste generation entirely is the best option to reduce emissions, protect health,
and minimize costs. However, once generated, there are many options for creating
environmental and economic benefit through the appropriate utilization organic waste.
Organics can be diverted to waste facilities with existing excess capacity, including
composting facilities, stand-alone anaerobic digesters (AD), and wastewater treatment
anaerobic digesters. New facilities can be also built in optimized locations.
In this analysis three scenarios were considered that can achieve the organic diversion
target outlined in this SLCP Strategy. The three scenarios are based on projected
waste data and potential diversion outlined in Appendix F. The only difference
between the scenarios is the waste utilization of grass and leaves. The three
scenarios evaluate the costs and revenues for utilizing food waste and grass and
leaves in three pathways:
1. New anaerobic digestion facilities
2. Existing excess capacity at wastewater treatment anaerobic digestion facilities
3. New compost facilities
The actual future utilization of food waste and grass and leaves will most likely be
some mix of these options. Since it is not possible to predict the exact mix of utilization
pathways, these three scenarios were developed to bound potential costs and
revenues. The scenarios considered here aim to balance cost and feasibility, while
prioritizing economic and environmental benefits. Although ARB recognizes there are
other beneficial uses of renewable natural gas, this analysis focuses on the capture
and pipeline injection of renewable natural gas from diverted organic waste. Using
renewable natural gas as a transportation fuel can result in significant potential
revenue streams and reduce criteria pollutant emissions from the transportation sector.
Prioritizing the use of biomethane as a transportation fuel may increase costs relative
to scenarios that focus solely on methane mitigation. However, important
environmental, health, and economic benefits may be most realized in disadvantaged
communities by prioritizing pipeline injection of renewable natural gas.
126 March 14, 2017
Within scenario 1, food waste and a portion of grasses and leaves are handled through
new centralized AD facilities and the resulting methane is pipeline injected. New AD
facilities are assumed to accept 100,000 tons per year of organic waste. The costs of
scenario 1 include facility construction and permitting, operating and maintenance
(O&M), waste and digestate processing and transportation, and the costs associated
with pipeline injection of renewable natural gas. These include pipeline,
interconnection, and biogas upgrading costs. Potential revenue streams include
tipping fees, the sale of biogas, LCFS credits, and RIN credits, as outlined in
Appendix F.
Scenario 2 assumes that food waste is diverted to wastewater treatment facilities with
existing excess capacity. The analysis assumes that, with modification, existing
wastewater treatment facilities can accept 50,000 tons of organic material per year on
average by 2025, with some facilities accepting more or less depending on size.
Costs for this scenario include upgrading and permitting costs that may be required for
facilities to accept food waste, waste and biosolids processing and transportation,
O&M, as well as the costs associated with pipeline injection of renewable natural gas.
Potential revenue streams include tipping fees, sale of biogas, LCFS credits, and RINs.
Scenario 3 assumes that all food waste and grasses and leaves are composted at new
facilities with a throughput of 100,000 tons per year. Costs within the scenario include
facility construction, O&M, and transportation of organic materials to the compost
facility. Compost facility revenues are estimated in scenario 3 by only including tipping
fees and not revenues associated with the sale of compost. This conservative
approach represents the lower bound estimate of compost. However, these revenues
vary depending on a number of factors such as seasonality, organic certification, and
compost blend type
A principal difference in outcomes from these three scenarios is the number of new
facilities needed to achieve the organic diversion targets. Table 18 shows the number
of new compost or AD facilities needed for each scenario.
182
Table 18: Estimated Number of New Facilities
Scenario
Estimated Number
of New Compost
Facilities
Estimated Number
of New AD Facilities
2020
2025
2020
2025
1. New AD
21
36
39
47
2. Existing WWTP
28
44
--
--
3. Compost Only
53
74
--
--
182
This analysis assumes existing wastewater treatment facilities can handle 50,000 wet tons of organic
material per year, while new AD facilities and compost facilities have a throughput of 100,000 wet tons
per year. Additional information regarding the projected organic waste streams by waste, the
assumptions surrounding required facilities, and the handling of residuals are presented in Appendix F
127 March 14, 2017
There is uncertainty regarding the costs, savings, and potential revenue streams
associated with organic waste diversion. Social welfare impacts, including those
related to health, noise, odor, ecosystem benefit, and water impacts, are not included
in this analysis but require additional consideration and analysis prior to the
implantation of any organic diversion measure. Additional uncertainty related to
existing infrastructure and technology development may also create economic impacts
not analyzed in this analysis, which relies on available data from California agencies,
academic researchers, and industry to estimate the direct economic impact, including
costs, fuel and energy savings, and potential revenue streams, of achieving the organic
waste diversion target in this SLCP Strategy.
Net present value calculations were used to estimate the potential profitability of the
three scenarios. By calculating the present value of future cost and organic diversion
over a 10-year financing period, the net present value calculation provides insight into
the feasibility of projects at the facility level, including the need for upfront grants and
incentives as well as the significant opportunities and uncertainty surrounding revenue
streams based on existing regulations.
Costs and revenues for the three scenarios are summarized in Table 19. The table
includes the net present value for each scenario over a 10-year financing period
Table 19: Cumulative Estimated Costs and Revenues by Scenario Over 10-Year
Accounting Period (Million Dollars)
Scenario 1: New AD
Component
Capital Cost
O&M
Revenue
New AD
47 Facilities
$2,400
$3,100
$7,000
New Compost
36 Facilities
$400
$400
$700
Total
$2,800
$3,500
$7,700
10-Year Net Present Value
$1,400
Scenario 2: WWTP
Component
Capital Cost
O&M
Revenue
New Compost
44 Facilities
$500
$500
$900
Existing Wastewater
Treatment
104 Facilities
$1,600
$2,800
$5,700
Total
$2,100
$3,300
$6,600
10-Year Net Present Value
$1,300
Scenario 3: Compost
Component
Capital Cost
O&M
Revenue
New Compost
74 Facilities
$900
$900
$1,700
Total
$900
$900
$1,700
10-Year Net Present Value
-$110
Table 19 suggests that under Scenario 1 and Scenario 2, organic waste diversion can
generate a positive return. These scenarios may also contribute to regional air quality
128 March 14, 2017
benefits, through reduced transportation emissions. However, revenue for these
strategies, and the resulting net present value, is highly dependent on the value of
LCFS and RIN credits. As shown in Table 20, for representative wastewater treatment
and new AD facilities, the net present value of diverting organic materials – at the
facility level – is negative without revenue from LCFS credits and RINs.
Table 20: Net Present Value of Representative Wastewater Treatment and New
AD Facility under Varying LCFS Credit Prices and RIN Credit Prices (Million
Dollars)
Wastewater Treatment Facility
New AD Facility
LCFS credit price
LCFS credit price
$0
$50
$100
$150
$200
$0
$50
$100
$150
$200
Cellulosic RIN credit
prices
$0.00
-$26.3
-$21.3
-$16.3
-$11.4
-$6.4
-$72.9
-$55.7
-$38.6
-$30.0
-$4.2
$0.50
-$17.2
-$12.3
-$7.3
-$2.3
$2.6
-$53.0
-$35.8
-$18.7
-$10.0
$15.7
$1.00
-$8.2
-$3.2
$1.7
$6.7
$11.6
-$33.1
-$15.9
$1.3
$9.9
$35.6
$1.85
$7.1
$12.1
$17.1
$22.0
$27.0
$0.8
$18.0
$35.2
$43.8
$69.5
$2.50
$18.9
$23.8
$28.8
$33.7
$28.7
$26.7
$43.9
$61.1
$69.7
$95.4
$3.00
$27.9
$32.8
$37.8
$42.8
$47.7
$46.7
$63.8
$81.0
$89.6
$115.3
$3.50
$36.9
$41.9
$46.8
$51.8
$56.7
$66.6
$83.8
$100.9
$109.5
$135.3
$4.00
$45.9
$50.9
$55.8
$60.8
$65.8
$86.5
$103.7
$120.9
$129.5
$155.2
State resources could be deployed to supplement financing of these types of
biomethane projects through mechanisms such as upfront grants, loan assistance
programs, and tax incentives. For example, the illustrative wastewater treatment
facility in Table 19 would break even over a 10-year financing period with an upfront
grant of $24 million. In the absence of revenue from the sale of LCFS or RIN credits, a
representative new AD facility would require an upfront grant of $67 million to
breakeven over a 10-year financing period. State agencies are collaborating to find
solutions to these financial challenges.
Altogether, this analysis suggests that the diversion of organic waste can result in
environmental and economic value to California. There are important uncertainties
associated with facility costs and potential revenues, however, which may limit project
development without additional support. In the absence of revenue from LCFS credits
and RINs, significant financial support may be required to achieve the targets identified
in this SLCP Strategy and deliver other environmental benefits. Through careful
research, investments, and structured market-based incentives, the State can work
with industry to significantly and permanently reduce methane emissions and divert
organic waste.
129 March 14, 2017
4. Greenhouse Gas Emission Standards for Crude Oil and Natural Gas
Facilities Regulation
This SLCP Strategy has a four-pronged approach to methane reductions in the oil and
gas sector including regulation of production, processing, and storage facilities and
implementation of SB 1371. The process to adopt rules and procedures to minimize
natural gas leaks from natural gas pipelines under SB 1371 is underway at the CPUC
and an analysis of the estimated costs and benefits of SB 1371 will be conducted as
measures are implemented.
ARB is developing a regulation to address methane from oil and gas production,
processing, and storage facilities for final Board consideration in 2017. The regulation
is anticipated to deliver environmental benefits that include an estimated reduction in
GHG emissions through 2030 of about 17.1 MMTCO
2
e from oil and gas related
emissions in California. In addition, the measure is expected to save about 820 million
standard cubic foot (scf) per year of industrial natural gas through reductions of leaks
and through vapor recovery systems, the monetized value of which is approximately
$2.8 million per year.
183
While air districts are currently combatting volatile organic compounds (VOC) leaks
locally, these rules vary by district and are not addressing any methane only leaks.
This measure is designed to expand upon existing local rules, promote statewide
uniformity, minimize the administrative burden on local air districts, harmonize state
requirements with current and near-future local and federal requirements, and achieve
further methane reductions to achieve the goal outlined in this strategy of reducing
fugitive methane emissions from all sources in the oil and natural gas sector by
45 percent by 2030.
The Oil and Gas measure proposes eight main control provisions that are designed to
achieve emission reductions in crude oil and natural gas operations. These provisions
build upon and in some ways increase existing local air district requirements to
monitor, replace, and expand current capital at crude oil and natural gas facilities.
The cost of this measure includes capital costs to: Install Vapor Recovery Units for
tanks, well stimulations tanks, and centrifugal compressors; replace rod packing on
reciprocating compressors; and change pneumatic devices. In addition, a leak
detection and repair program (LDAR) as well as emission reductions and leak
monitoring plans at underground gas storage facilities will have ongoing costs in each
year beginning in 2018. The amortized
184
capital cost plus the ongoing costs yield an
overall cost of the measure of just over $360 million through 2030. These costs are
offset by natural gas collection from the reduction in leaks and vapor recovery; these
savings amount to savings of almost $34 million through 2030 and persisting
183
http://www.energy.ca.gov/2014publications/CEC-200-2014-001/CEC-200-2014-001-SF.pdf. Using a
value of $4.10 per Mscf, which is the value of the natural gas prices are based upon wholesale prices
that are forecasted by the California Energy Commission using their NAMGas general equilibrium model.
184
Using a 5% discount rate.
130 March 14, 2017
thereafter. The costs, cost-savings, and emission reductions are outlined in Table 21
by each provision.
Table 21: Costs and Emissions for Oil and Gas Measure
Segment of
Regulation
Total
Reductions
to 2030
(MTCO2e)
Annual
Cost
Annual
Savings
Total Cost
to 2030
Total
Savings to
2030
VRU for Tanks
6,452,465
$4,699,168
$498,259
$56,390,016
$5,979,108
Reciprocating
Compressors
814,026
$257,496
$178,042
$3,089,952
$2,136,504
LDAR
5,913,461
$12,864,526
$1,293,380
$154,374,312
$15,520,560
Pneumatic
Devices
3,828,658
$1,153,309
$837,396
$13,839,708
$10,048,752
Well
Stimulations
59,100
$463,400
$0
$5,560,800
$0
Centrifugal
Compressors
42,282
$6,475
$9,250
$77,700
$111,000
Monitoring Plan
0
$10,625,815
0
$127,509,780
0
Total
17,109,992
$30,070,189
$2,816,327
$360,842,268
$33,795,924
5. Hydrofluorocarbon (HFC) Emission Reductions
Note: The following HFC section was written before the global phasedown of HFCs
was agreed to on October 15, 2016 (the “Kigali Amendment”). ARB is currently
evaluating the Kigali Amendment’s impact upon HFC emissions in California; this
section will be further updated to reflect changes in BAU emissions, additional needed
reductions, and the cost and benefit of HFC reductions measures.
Hydrofluorocarbons (HFCs) are used primarily as refrigerant substitutes to ozone-
depleting refrigerants, and although not ozone-depleting, HFCs have high-global
warming potentials (GWP) between 500 and 12,000 (20-year GWP values). HFCs
currently account for four percent of California’s GHG emissions, but are expected to
131 March 14, 2017
double in emissions in the next few decades without additional reduction actions. Four
HFC measures are proposed in this strategy to reduce cumulative HFC emissions by
260 MMTCO
2
E (20-year GWP) by 2030 to meet the SLCP emission reduction target.
The proposed reduction measures include the following:
Financial incentive program to install new low-GWP refrigeration and air-
conditioning (AC) equipment
Sales ban on refrigerants with very-high GWPs
Phasedown in the supply of high-GWP HFCs (to be enacted through the
international agreement of the Montreal Protocol Meeting of the Parties, October
15, 2016, in Kigali, Rwanda)
Prohibitions on high-GWP refrigerants in new stationary refrigeration and AC
equipment
The cost of strategies to reduce HFCs is highly dependent upon assumptions of the
added initial cost of low-GWP equipment, which is estimated to be approximately
10 percent higher than baseline high-GWP equipment, as detailed in Appendix F. The
additional initial cost ranges from $500,000 for a large cold storage facility, and
$200,000 for a supermarket; to $400 for a residential AC system, and $140 for a
residential refrigerator-freezer. In many cases, the added initial cost is offset or
reversed through energy savings of low-GWP refrigeration and AC. Additionally, low-
GWP refrigerants such as carbon dioxide refrigerant, ammonia, and hydrocarbons are
less expensive than HFCs. The main barrier to adoption of low-GWP refrigeration
equipment is the added initial cost. For low-GWP AC, the barriers include added initial
cost and current building codes that do not allow very slightly flammable low-GWP
refrigerants.
Measure costs were derived using the incremental per-unit equipment cost over the
number of new units replacing retiring units each year. The total cost savings result
from less energy use and less expensive refrigerant over the lifetime of the equipment.
The cumulative costs and savings are outlined in Table 22.
The cost and savings from HFC reduction measures were estimated separately for
each measure and then summed together to show total estimated cost and total
estimated savings from all measures. This approach was used to avoid double-
counting emission reductions, cost, and savings from measures that overlap
significantly. For example, businesses installing low-GWP refrigeration because of the
early adoption incentive program would not be subject to required prohibitions of high-
GWP refrigerant in new equipment, and would not be affected by an HFC
phasedown. An HFC phasedown could incentivize new equipment to use low-GWP
refrigeration and AC, and a prohibition on high-GWP refrigeration and AC would largely
overlap with HFC phasedown requirements. Detailed cost and savings for each
individual measure are presented in Appendix F.
132 March 14, 2017
Table 22: HFC Measure Costs and Savings through 2030 (Million Dollars)
Total Cost
Total
Savings
Net Cost
Emission
Reductions
(MMTCO2e)
HFC Reduction
Measures
$5,060
($4,850)
$210
260
GHG reductions from direct refrigerant emissions are estimated by modeling
equipment sectors using a constant refrigerant charge size and annual leak rate, with
the only variable that of the refrigerant’s GWP. The reduction per unit per year is the
difference between the emissions of the high-GWP equipment and the emissions
expected from the new, low-GWP equipment. Indirect GHG emissions from less
energy usage were also estimated using the default carbon intensity of California’s
electricity from the Cap-and-Trade Program. Note that the indirect emission reductions
account for less than four percent of GHG reductions from refrigeration and AC (the
carbon intensity of electricity generation used to power cooling equipment is
overwhelmed by the very-high GWPs of HFC refrigerants).
B. Public Health Assessment
Short-lived climate pollutants are not only powerful climate forcers but are also harmful
air pollutants with many direct and indirect impacts on health. The focused efforts
identified in this SLCP Strategy will not only help to limit the impacts of climate change
that are already underway, but also reduce local air pollution and produce other co-
benefits. The World Health Organization (WHO) describes the direct and indirect
impacts of SLCP emissions, on a global level, as follows:
185
Since SLCPs contribute to ambient levels of ozone and PM2.5, SCLP [sic]
emissions are directly associated with cardiovascular and respiratory diseases,
including heart disease, pulmonary disease, respiratory infections and lung
cancer. SLCP emissions thus contribute significantly to the more than 7 million
premature deaths annually linked to air pollution.
Indirectly, the SLCPs, ozone, and black carbon reduce plant
photosynthesis and growth, thus decreasing agricultural yields, which in
turn threatens food security. They also affect weather patterns and the
melting of snow and ice, which may harm and endanger health through
extreme weather events such as floods.
185
World Health Organization, “Reducing global health risks through mitigation of short-lived climate
pollutants,” accessed April 1, 2016. http://www.who.int/phe/health_topics/outdoorair/climate-reducing-
health-risks-faq/en/
133 March 14, 2017
Furthermore, in its report on Reducing global health risks through mitigation of short-
lived climate pollutants,
186
the WHO notes that certain efforts to cut emissions of
SLCPs may provide other types of health benefits not associated with air pollution.
These include improved diets or more opportunities for safe active travel and physical
activity. As described in this SLCP Strategy, some strategies to cut emissions of
SLCPs in California could have important benefits for water quality, and potentially for
water supply in the State, as well.
The measures and goals identified in this SLCP Strategy could deliver many of these
types of benefits in California, which might accrue especially in disadvantaged
communities (see Section C). As they are further developed and implemented, it will
be important to consider a broad array of potential impacts and benefits to ensure that
prioritized strategies to cut SLCP emissions also maximize other health benefits. For
example, as part of an integrated strategy that includes use of ultra-low-NOx vehicles
and renewable natural gas in the transportation sector, converting manure
management operations to scrape systems and injecting renewable natural gas into
the pipeline can help to improve air quality and water quality near dairies and
elsewhere in California. A discussion of the health impacts associated with the
measures in this SLCP Strategy is provided below. A more detailed public health
impacts analysis will be developed as part of any potential subsequent regulatory
process.
Black carbon is a component of fine particulate matter (PM2.5). A large number of
studies, particularly epidemiological (population-based) studies, have linked exposure
to PM2.5 to a number of adverse health effects, including premature death, hospital
admissions for the worsening of chronic cardiovascular and lung diseases, and
emergency room visits for asthma.
187
,
188
,
189
Diesel particulate matter is a subset of
PM2.5, and consists of black carbon particle cores that are coated with a variety of
other chemical substances, including over 40 carcinogenic organic compounds,
nitrates, sulfates, and heavy metals. To date, no studies have directly investigated
potential health effects of black carbon. However, since black carbon particulate
matter is a subset of PM2.5, which has been clearly shown to be related to adverse
health effects, the scientific community has concluded that diesel and black carbon
particulate matter likely have similar adverse effects as PM2.5. As part of its periodic
186
WHO (2015) Reducing global health risks through mitigation of short-lived climate pollutants,
Summary report for policymakers, World Health Organization, October.
http://www.who.int/phe/publications/climate-reducing-health-risks/en/
187
Krewski D., Jerrett M., Burnett R.T., Ma R., Hughes E., Shi Y., Turner M.C., Pope C.A. III, Thurston
G., Calle E.E., Thun M.J.. 2009. Extended Follow-Up and Spatial Analysis of the American Cancer
Society Study Linking Particulate Air Pollution and Mortality. HEI Research Report 140. Health Effects
Institute, Boston, MA. http://www.healtheffects.org/Pubs/RR140-Krewski.pdf
188
Bell M.L., Ebisu K., Peng R.D., Walker J., Samet J.M., Zeger S.L., Dominici F. 2008. Seasonal and
regional short-term effects of fine particles on hospital admissions in 202 U.S. counties, 1999–2005. Am
J Epidemiol 168:1301–1310.
189
Ito, K., G. D. Thurston and R. A. Silverman. 2007. Characterization of PM2.5, gaseous pollutants, and
meteorological interactions in the context of time - series health effects models. J Expo Sci Environ
Epidemiol. Vol. 17 Suppl 2: S45 - 60.
134 March 14, 2017
reviews of the national ambient air quality standards, the U.S. EPA draws conclusions
as to the strength of the relationship between exposure to air pollution and broad
categories of adverse health effects. In its most recent integrated science assessment
for the PM standards, it concluded that PM2.5 plays a “causal” role in premature death
and cardiovascular effects, and a “likely causal” role in respiratory effects.
190
As a result of State and local efforts over the past decades to improve air quality,
California has significantly cut particulate matter emissions from anthropogenic
sources, especially from diesel engines. The result is that black carbon emissions are
about 90 percent lower than they were in the 1960s and approximately 5,000
premature deaths are avoided in the State each year. Current NO
x
and PM emission
standards for on-road and off-road diesel engines that phase in between 2012 and
2020 will lead to significant additional reductions in primary PM2.5 emissions from
diesel equipment.
191
(NO
X
emissions are also projected to decrease, which could
reduce ozone and secondary PM.) As a result, the health-related impacts associated
with diesel PM2.5 are expected to continue to decrease through 2030.
Residential wood burning (fireplaces and woodstoves) is another important source of
black carbon emissions and local air pollution, and its share of the State’s black carbon
inventory is increasing, as emissions from diesel engines fall. Fireplaces and
woodstoves produce PM2.5, carbon monoxide, volatile organic compounds, and
hazardous air pollutants. In ARB’s black carbon inventory, emissions from these
sources are assumed to increase between 2013 and 2030, due to increased residential
construction. Actions outlined in this SLCP Strategy, such as restricting residential
wood-burning fireplaces and promoting the conversion to cleaner wood-burning stoves,
can help reduce these emissions and health-related impacts, which especially impact
rural areas.
Methane contributes to global background levels of ozone in the lower atmosphere
(troposphere). Global background ozone (tropospheric ozone) concentrations have
roughly doubled since preindustrial times, and are projected to continue to increase.
Ozone itself is a powerful SLCP as well as a regional ground level air pollutant. Ozone
exposure has been linked to increases in emergency room visits for worsening of
asthma, hospitalizations due to respiratory disease, and premature death. Additionally,
ozone suppresses crop yields; harms ecosystems; and affects evaporation, cloud
formation, and precipitation.
192
Thus, reducing methane emissions as part of a broader
190
U.S. EPA. 2009. Integrated Science Assessment for PM. U.S. Environmental Protection Agency,
Washington, DC Publication EPA/600/R-08/139F.
http://www.epa.gov/ttn/naaqs/standards/pm/s_pm_2007_isa.html
191
Primary particles are directly released into the atmosphere by combustion processes (such as soot or
black carbon and a large variety of organic carbons). “Secondary” particles also form in the atmosphere
from other gaseous pollutants, particularly sulfur dioxide, nitrogen oxides (NO
X
), ammonia, and volatile
organic compounds (VOCs). The transportation sector is an important source of secondary particulate
matter such as ammonium nitrate, especially in the winter.
192
UNEP and WMO (2011) Integrated Assessment of Black Carbon and Tropospheric Ozone, United
Nations Environment Programme and World Meteorological Association.
http://www.unep.org/dewa/Portals/67/pdf/BlackCarbon_report.pdf.
135 March 14, 2017
effort to address climate change can complement local and regional efforts to reduce
ground-level ozone.
Strategies to reduce methane emissions from dairy manure management can deliver
important health benefits, especially if developed as part of a systematic approach to
addressing air quality and water quality. For example, converting operations to
pasture-based systems would likely reduce concentrations of and exposure to
potentially harmful constituents, such as hydrogen sulfide, ammonia, and particulate
matter. One study suggests that ammonia emissions could be 30 percent lower for
pasture-based than for confinement systems.
193
It could also improve nutrient
management on farms, helping to reduce soil and groundwater contamination. This
strategy could be an important element of a sector-wide approach to reducing dairy
methane emissions, but may have limited applicability. ARB estimates that about 25
dairies in the State could convert to pasture-based operations without reducing herd
size or procuring new land.
Other strategies could also deliver environmental and health benefits. Converting
dairies from flushwater manure management systems to dry manure management
systems could also improve nutrient management, thereby potentially helping to
improve groundwater quality. It is possible that farms may choose some management
strategies which could increase or decrease emissions of pollutants of concern. If
emissions increase, measures should be implemented to mitigate the impacts as part
of the permitting process.
Strategies that capture or produce methane and utilize it for production of renewable
energy and fuels could lead to additional sources of combustion, but as part of a
regional approach to utilize low-NO
x
vehicles and renewable fuels, can displace diesel
combustion and help to improve air quality. If electricity is generated onsite using dairy
derived biogas, using microturbines or fuel cells can minimize new emissions of NO
x
and PM, minimizing potential local health impacts. To the extent that renewable
natural gas is produced and injected into the natural gas pipeline network, or used in
low-NO
x
engines to displace diesel combustion, air quality impacts can be avoided.
Prioritizing pipeline injection and onsite usage in low-NOx vehicles, in addition to a
coordinated effort to increase use of low-NO
x
vehicles with renewable fuels in areas
surrounding dairies and elsewhere can reduce air pollution regionally and statewide.
These emission reductions translate directly into health benefits, especially in
disadvantaged communities near dairies and along transportation corridors, and in
areas of non-attainment for ambient air quality standards.
Diverting organics from landfills to compost facilities and anaerobic digestion facilities,
along with implementing food recovery programs, will significantly reduce the need for
further landfill development in California, and may help increase the efficacy of landfill
gas management systems at existing landfills, many of which are located in or near
environmental justice communities. Phasing out the landfilling of organic materials will
193
Perry, A. (2011) Putting dairy cows out to pasture: An environmental plus, USDA-ARS Agricultural
Research Magazine, May-June. http://www.ars.usda.gov/is/AR/2011/may11/cows0511.htm
136 March 14, 2017
also help reduce future levels of fugitive methane emissions from landfills during their
operational and post-closure stages. The number and frequency of heavy vehicle or
truck trips to existing landfills, through neighboring communities, could potentially be
reduced as organic materials are directed to anaerobic digestion facilities and regional
compost facilities. To the extent that truck trips are reduced to and from landfills, they
could increase in areas where facilities handling diverted organic waste are located.
The net effect on overall truck trips in the State and associated emissions is uncertain,
and could potentially increase as a result of changes in organic waste management,
depending on how strategies are implemented. Many of the same issues associated
with landfilling organic waste—potential criteria pollutant emissions, water quality
impacts, and odors—could be issues at anaerobic digestion or compost facilities. In
many cases, these can be effectively limited with available technologies and
management strategies, including limiting trucking emissions by utilizing zero emission
vehicles or renewable natural gas in low-NO
x
engines associated with these
operations.
Food recovery could deliver additional potential health benefits by utilizing useable
food to relieve food insecurity and provide better access to healthy foods. Increasing
edible food recovery—especially from large-scale food producers, processors, and
users—and safely redirecting food to those in need could increase access to healthy
fruits and vegetables and benefit millions of Californians who suffer from food
insecurity.
Reducing leaks from the oil and gas sector will also reduce VOC emissions, which
contributes to ground level ozone formation and related health impacts. For example,
ARB's oil and gas regulation is expected to reduce VOC emissions and toxic air
contaminants that are emitted from uncontrolled oil and water storage tanks and
released from well stimulation recirculation tanks. The estimated reduction in VOCs
from this measure is approximately 3,600 tons per year, or about 10 tons per day,
statewide.
The measures identified in this SLCP Strategy for HFCs are unlikely to have noticeable
health impacts. HFCs have negligible impacts on smog formation and are exempt from
U.S. EPA’s definition of volatile organic compounds. At higher concentrations that
could result from an accidental release in occupational settings, they might be toxic,
and emissions of vapors containing HFCs in the workplace environment should be
prevented. But at ambient concentrations, HFCs pose no significant health risk, and
efforts described in this SLCP Strategy to phase down their use are not expected to
deliver noticeable health benefits. Some potential replacements for HFCs could result
in emissions of VOCs and particulate matter, but they would be negligible.
C. Environmental Justice and Disadvantaged Communities
The State of California defines environmental justice (EJ) in statute as "the fair
treatment of people of all races, cultures, and incomes with respect to the
development, adoption, implementation, and enforcement of environmental laws,
137 March 14, 2017
regulations and policies" (Government Code section 65040.12). ARB is firmly
committed to seeking fair treatment of all races, cultures, and incomes in the measures
it develops and implements.
194
ARB works extensively with local air districts, EJ
communities and other stakeholders during the development and implementation of its
programs to respond to concerns about environmental justice.
AB 32 (Statutes of 2006, Chapter 488), directs ARB to convene an Environmental
Justice Advisory Committee (EJAC) to advise the Board in developing the Scoping
Plan, and any other pertinent matter associated with the implementation of AB 32. In
January 2007, the Board appointed the first EJAC to advise it on the Initial Scoping
Plan before that plan was approved by the Board in December 2008. The EJAC was
reconstituted in March 2013 to advise the Board on the First Update to the Scoping
Plan. The EJAC is now advising ARB on the development of the 2017 Scoping Plan
Update. As part of that process, staff worked with the EJAC to hold eleven community
meetings around the state. The recommendations that emerged from that process are
being incorporated into or otherwise addressed in the 2017 Scoping Plan Update.
As part of its ongoing effort to fully integrate environmental justice considerations into
its programs, ARB has created the position of Assistant Executive Officer (AEO) for
Environmental Justice. The AEO will serve as the primary internal and external contact
for ARB on EJ issues and concerns. The AEO will be responsible for providing policy
consultation and recommendations to ARB staff, and will participate in decision making
during the development and implementation of all major ARB programs to ensure that
EJ concerns are fully considered. The AEO will develop and implement a program to
ensure that EJ concepts, values and objectives are understood and considered
throughout the development and implementation of the ARB’s policies and
programs. Further, the AEO will develop and maintain relationships with EJ
stakeholders, and enhance communication between external stakeholders and ARB
program staff.
ARB briefed the current EJAC on the development of the SLCP Strategy on several
occasions. The EJAC has met fifteen times since December 2015, developed Initial
Recommendations on August 26, 2016, and further refined their recommendations on
December 22, 2016. The EJAC’s Recommendations consist of about 150
recommendations, sorted by six broad categories:
1) Overarching Issues;
2) Industry;
3) Energy, Green Buildings, and Water;
4) Transportation;
5) Natural and Working Lands, Agriculture, and Waste; and
6) California Climate Investments.
Recommendations falling under these broad categories were then further grouped into
five subcategories:
194
See https://www.arb.ca.gov/ch/programs/ej/ejpolicies.pdf.
138 March 14, 2017
(A) Partnership with Environmental Justice Communities;
(B) Equity;
(C) Coordination;
(D) Economic Opportunity; and
(E) Long-Term Vision.
The EJAC provided direction that their Recommendations are intended “to be read and
implemented holistically and not independently of each other.” ARB will provide
responses to each Recommendation as the 2017 Scoping Plan is developed. The
complete set of Recommendations is available at:
https://www.arb.ca.gov/cc/ejac/ejac_recommendations_proposed_plan122216.pdf.
The EJAC recommendations that are relevant to this SLCP Strategy, and ARB’s
responses to those recommendations, follow:
(1) Address localized impacts of short-lived climate pollutant emissions, such as black
carbon from all sources.
This SLCP strategy describes a comprehensive array of measures to reduce methane,
black carbon, and HFC emissions in California. SB 1383 directs ARB to develop
measures to reduce black carbon from anthropogenic sources. As such, the strategy
supports measures in place and under development that reduce black carbon from
mobile sources, proposes new measures to reduce black carbon emissions from wood-
burning stoves, and proposes next steps to foster emission reduction from other
sources such as agricultural burning. These black carbon emission reductions will
benefit climate, local air quality, and health.
(2) Divert dairy waste as fertilizer and for carbon sequestration before it can be
converted to methane.
The dairy and livestock section of this SLCP Strategy describes a range of potential
methane reduction measures that will be considered under future incentive and
regulatory programs. Among them are measures in which manure would be used as a
soil conditioner and fertilizer without first being digested. Because the measures
developed under the SLCP program must be technically and economically feasible,
and must not lead to emissions leakage, no measures can be ruled out at this point in
the process. All measures eventually adopted under the SLCP program, however,
must also avoid adverse impacts to disadvantaged communities.
(3) Perform a complete lifecycle analysis of dairy and other bio-digester technology and
related infrastructure investment. If biogas from dairies is converted to bio-
methane, ARB must mandate that vehicles servicing digesters and converters
utilize that gas as a primary fuel source. This is a better use of the fuel than
building new pipelines and related infrastructure to transport the gas to other
locations.
139 March 14, 2017
Before biomethane can generate credits under the LCFS, it must obtain a carbon
intensity (CI) value. A CI is a full lifecycle GHG emissions value. Depending on credit
values, much of the vehicle fuel produced from dairy manure biogas will have LCFS CI
values. In general, however, ARB is obligated to account for all emissions in the
measures it develops. SB 1383 is clear that we are not to develop methane measures
that produce adverse air quality impacts. It will therefore be important to avoid
significant increases in vehicular and equipment emissions. Measures that result in the
use of dairy digester biomethane in vehicles and equipment servicing dairy digester
projects is one way to achieve this goal. Digester biomethane in excess of what can
feasibly be used locally, however, must be transported to markets.
(4) Identify and establish effective methods for implementing food rescue programs,
with quality controls to avoid dumping inedible food on communities; divert expired
food to composting. Identify strategies for getting edible food to those who need it.
Incentivize these programs and promote communication plans for projects, so all
communities have access to successful plans.
SB 1383 requires CalRecycle, in consultation with ARB, to develop regulations to
reduce disposal of organic waste by 50 percent of 2014 levels by 2020 and 75 percent
by 2025. Of the edible food in the organic waste disposal stream, not less than
20 percent is to be recovered to feed people in need by 2025. In public workshops
held on February 14
th
and 16
th
, 2017, CalRecycle articulated its intent to divert safe,
recoverable food fit for human consumption. Other food in the waste stream would be
diverted for composting and other uses, in keeping with the statutory 50 and 75 percent
diversion proportions. CalRecycle also discussed ideas for sharing program examples,
including through its website.
(5) Develop more local agricultural processing centers so food is not being trucked long
distances. Introduce a scoring system for food that indicates food-miles traveled.
Encourage local food processing of food and meat, and educate people on the
greenhouse gas reduction benefits of not eating meat. Establish public financing for
healthy, environmentally sound food sources.
These are potentially viable measures. Staff will consider them in the development of
measures to reduce methane emissions under this SLCP Strategy.
(6) Regulate the dairy industry and give them a debit for methane emissions not
avoided, along with credits for methane capture (negative carbon credit). This will
help provide an accurate accounting of their inputs and outputs.
This would constitute a departure from long-established LCFS methodology. Carbon
intensities are calculated as a change from the pre-fuel production baseline. In this
case, the change would be a large reduction in methane emissions. The only way
ongoing emissions could be debited would be if they, like the reductions, resulted from
the fuel production process.
140 March 14, 2017
(7) The 40% reduction of dairy methane shown in the Scoping Plan is not likely to
happen by 2030, but it is a critical part of reaching the goal. Provide an alternative
plan of how that methane would be reduced without it.
All technically and economically feasible measures to reduce dairy methane emissions
will have been implemented by 2030. We are confident these measures will achieve
the necessary reductions. In the unlikely event they fall short, the difference would
most likely have to be made up elsewhere in the economy.
(8) No credits must be given for landfill or for biodigestors for greenhouse gas
avoidance. . . the state already recognizes the benefits of using compost (from
food, paper, wood, yard waste, and other natural materials in the waste stream) to
store carbon in the soil. . . . Disincentivize and discourage locating biomass and
digesters in disadvantaged communities or in close proximity to housing...Do not
promote the use of landfills and dairies becoming energy producing facilities as a
way of sequestering carbon. There are huge natural gas reserves now, to the point
where some is flared. Landfills and dairies should not be used to produce more to
sell. If natural gas is produced at these facilities, it must be used to power the site
and vehicles at the site.
The points in this comment will be discussed in the order they were raised:
a) Regarding credits for avoided emissions due to anaerobic digesters and landfill
measures, State agencies have endorsed the strategy of crediting avoided
emissions from dairy digesters, as found in EJAC recommendation 6, above.
Recommendation 6 encourages the State to credit dairy methane emissions
avoided (The follow-up recommendation that emissions not avoided be debited
is responded to above). Crediting avoided emissions from other organic wastes
is consistent with this approach to reducing dairy emissions.
b) Regarding the siting of organic waste processing facilities relative to
disadvantaged communities and housing, SB 1383 requires that the State’s
SLCP measures create benefits for, and avoid impacts to, disadvantaged
communities. In developing measures to reduce methane emissions from the
State’s waste streams, State agencies and project developers will work in close
consultation with communities, and will ensure that benefits to communities are
maximized and impacts avoided, as required by SB 1383. This will extend to
facility siting decisions.
c) Regarding the conversion of organic wastes (dairy manure and organic wastes
that are currently landfilled) to energy, the magnitude of the waste diversion
problem in California will require that all options remain available. While
composting may be a viable solution in one area, it may not be viable in another.
Moreover, conversion of wastes to biomethane produces a significant climate
benefit by displacing fossil natural gas and diesel. The climate benefits of
biomethane are reflected in the very low carbon intensities the Low Carbon Fuel
141 March 14, 2017
Standard has assigned to fuels derived from anaerobically digested organic
wastes. When used as a vehicle fuel, for example anaerobically digested food
and green waste has a carbon intensity of -22.93 grams of CO
2
-equivalent
emissions per mega joule of fuel energy. This benefit is not reduced by the
current abundance of fossil gas. State agencies agree, however, that utilizing
biomethane for vehicle fuel in close proximity to where that fuel is produced can
produce additional benefits. If diesel emissions are displaced near communities
and/or in non-attainment areas, local communities realize tangible air quality
benefits.
ARB staff has been working with staff from other state agencies to develop a holistic
and synergistic approach to reducing methane emissions, and will continue to work
with them to develop and implement these measures. ARB staff will continue to
consult with EJ communities as we develop and implement the measures to ensure
minimum impact and maximum benefit to environmental justice communities.
Furthermore, the EJAC recommendations will be taken into consideration as specific
actions and policies discussed in this SLCP Strategy are developed into regulatory and
non-regulatory measures and policies.
The California Environmental Protection Agency, pursuant to Senate Bill 535 (De León,
Chapter 830, Statutes of 2012), has identified the communities in California that are
most disproportionately burdened by pollution for the purposes of expenditure of
California Climate Change Investment Funds. Of the 12 indicators of pollution included
in its methodology, three are directly related to SLCP emissions (fine particle
emissions, diesel particulate emissions, and solid waste sites and facilities), and at
least six others (mostly related to water quality and air quality) are at least related to
sources of SLCP emissions.
195
The distribution of these communities often aligns with locations of SLCP emission
sources, including sources of organic waste streams and dairies in the Central Valley;
ports and freight corridors in the East Bay, Los Angeles area and Inland Empire; and
oil production, landfills and other sources of SLCP emissions throughout the State.
Many communities in these areas have some of the worst pollution burdens in the
State and high rates of poverty and unemployment. Rural communities in the northern
part of the State and the Sierra also are stricken with high rates of poverty and
unemployment. Many billions of dollars in public and private investment will flow to
communities in all of these regions in the coming years to reduce SLCP and CO
2
emissions, strengthen our agricultural sector, and build sustainable freight systems.
The integrated strategy to reduce SLCP emissions from agriculture and waste,
developed in this SLCP Strategy, can be part of an integrated strategy to improve air
and water quality in agriculture regions, such as in the Central Valley. Additionally, the
Healthy Soils Initiative will improve California’s agriculture economy and support further
economic development in these communities.
195
http://oehha.ca.gov/calenviroscreen/indicators
142 March 14, 2017
The measures identified in this SLCP Strategy will be further developed in a formal
public process that specifically considers environmental justice concerns.
Opportunities for public participation will be provided during the development of each
measure, and regulatory language will be made available in easily understood and
useful formats, such as program-specific webpages and slide presentations.
D. Environmental Analysis
ARB, as the lead agency for the SLCP Strategy, prepared a draft environmental
analysis in accordance with its certified regulatory program (Cal. Code Regs., tit. 17,
§§ 60000 – 60008) to comply with the requirements of the California Environmental
Quality Act (CEQA) (Pub. Resources Code, §21000, et seq.). The Revised Draft
Environmental Analysis prepared for the Revised Proposed Short-Lived Climate
Pollutant Reduction Strategy (Revised Draft EA) and included as Appendix E to the
SLCP Strategy, provided an analysis of the potential environmental impacts associated
with implementing the recommended measures in the SLCP Strategy. Following
circulation of the Revised Draft EA for a 45-day public review and comment period from
November 28, 2016, through January 17, 2017, ARB prepared the Final Environmental
Analysis prepared for the Revised Proposed Short-Lived Climate Pollutant Reduction
Strategy (Final EA) which includes minor revisions to the Revised Draft EA. The Final
EA is included in Appendix E to the final SLCP Strategy and was posted on ARB’s
SLCP website in March 2017.
The Final EA was prepared in accordance with the requirements of the California
Environmental Quality Act (CEQA) and ARB’s regulatory program certified by the
Secretary of Natural Resources (California Code of Regulation, title 17, sections
60006-60008; California Code of Regulation, title 14, section 15251, subdivision
(d)). The resource areas from the CEQA Guidelines Environmental Checklist were
used as a framework for a programmatic environmental analysis of the reasonably
foreseeable compliance responses resulting from implementation of the proposed
measures discussed in this SLCP Strategy. The Final EA provides an analysis of both
the beneficial and adverse impacts and feasible mitigation measures for the reasonably
foreseeable compliance responses associated with the proposed measures under
each of the environmental resource areas.
Collectively, across all categories, the Final EA finds the reasonably foreseeable
compliance responses associated with implementation of the proposed measures in
the SLCP Strategy could result in the following short-term and long-term impacts:
beneficial long-term impacts to air quality and greenhouse gas emissions; less than
significant impacts, or no impacts, to aesthetics, agriculture and forest resources, air
quality, biological resources, cultural resources, energy demand, geology and soils,
greenhouse gases (short-term), hazards and hazardous materials, hydrology and
water quality, land use and planning, mineral resources, noise, population and housing,
public services, recreational services, transportation and traffic and utilities and service
systems; and potentially significant impacts to aesthetics, agriculture and forest
resources, air quality, biological resources, cultural resources, geology and soils,
143 March 14, 2017
hazards and hazardous materials, hydrology and water quality, land use and planning,
noise, transportation/traffic, and utilities and service systems. The potentially
significant and unavoidable adverse impacts are primarily related to short-term
construction-related activities. This explains why some resource areas are identified
above as having both less-than-significant impacts and potentially significant impacts.
144 March 14, 2017
IX. Next Steps
The final proposed SLCP Strategy, the final Environmental Analysis (Final EA), and
written responses to comments received on the Revised Draft EA have been posted to
ARB's SLCP website and will be presented to the Board for consideration for approval
in March 2017.
SB 1383 requires ARB to begin implementing the SLCP Strategy by January 1, 2018,
as well as specifies timeframes for other requirements (see Table 23). ARB staff, along
with staff from other state agencies, have already begun efforts to implement most of
these requirements.
Table 23: Timeline for SB 1383 Mandates
Action
Deadline
ARB approves SLCP Strategy and begins Implementation
Expected approval date………………………………………
Statutory deadline…………………………………………….
First Quarter 2017
By January 1, 2018
ARB, CDFA, State Water Resources Control Board and
Regional Water Quality Control Boards in coordination with
the energy agencies, will work with the dairy industry to
establish a dairy workgroup to identify and address barriers
to the collection and utilization of biomethane.
First Quarter 2017 and ongoing
CPUC, in consultation with ARB and CDFA, directs utilities
to develop at least 5 dairy biomethane pipeline injection
projects
By January 1, 2018
ARB develops a pilot financial mechanism to reduce LCFS
credit value uncertainty from dairy-related projects and
makes recommendations to the Legislature to expand the
mechanism to other biogas sources
By January 1, 2018
ARB provides guidance on the impact of regulations on
LCFS credits and compliance offsets
By January 1, 2018
ARB, in consultation with CPUC and CEC, develops policies
to encourage development of infrastructure and biomethane
projects at dairy and livestock operations
By January 1, 2018
CEC develops recommendations for the development and
use of renewable gas as part of its 2017 Integrated Energy
Policy Report
By early 2018
PUC renewable gas policies based on CEC IEPR
Ongoing
ARB, in consultation with CDFA, evaluates the feasibility of
enteric fermentation methane reduction incentives and
regulations and develops regulations as appropriate
Ongoing
CalRecycle adopts an organics disposal reduction regulation
By end of 2018
145 March 14, 2017
Action
Deadline
ARB, in consultation with CDFA, analyzes and reports on
the methane reduction progress of the dairy and livestock
sector
By July 1, 2020
CalRecycle, in consultation with ARB, evaluates progress
towards meeting the 2020 and 2025 organics waste
reduction goals, the status of organics markets and barriers,
and recommendations for additional incentives
By July 1, 2020
CalRecycle implements an organics disposal reduction
regulation
On or after January 1, 2022
ARB begins developing and considers for adoption a
manure management methane reduction regulation
Before January 1, 2024
ARB implements a manure management methane reduction
regulation
On or after January 1, 2024
All regulatory measures developed pursuant to this SLCP Strategy will be subject to its
own public process with workshops, opportunities for stakeholder discussion,
consideration of environmental justice, and legally required analyses of the economic
and environmental impacts. While this SLCP Strategy is intended to be comprehensive,
it is not exhaustive. We will continue to pursue new cost-effective programs and
measures as technology and research on SLCP emission sources and potential
mitigation measures advances. Staff will track the progress of implementation of the
SLCP measures and provide periodic updates to the Board. This information, as well
as updates to the SLCP emission inventory, will be posted to ARB’s SLCP website.
Effectively implementing this SLCP Strategy will require staff to continue working with
local, regional, federal and international partners, while strategically investing time and
money to overcome market barriers that hinder progress. As our efforts continue, our
progress toward these goals will accelerate, leading to a wide range of significant
economic and environmental benefits for California broadly, and many of the State’s
most disadvantaged communities, specifically.